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Report to Executive Agency Officials:
October 2002:
INVASIVE SPECIES:
Clearer Focus and Greater Commitment Needed to Effectively Manage the
Problem:
GAO-03-1:
Letter:
Results in Brief:
Background:
More Comprehensive Analysis of the Economic Impacts of Invasive Species
Would Better Inform Decision Makers:
The National Management Plan Lacks a Clear Long-Term Outcome, and Its
Implementation Has Been Slow:
The Current Regulations Concerning Ballast Water Management Are Not
Keeping Invasive Species Out of the Great Lakes:
There Is a Growing Interest in Coordination between the United States
and Canada, but a Comprehensive Approach Has Yet to Be Developed:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Survey of Charter Members of the Invasive Species
Advisory Committee:
Appendix III: Comments from the Department of the Interior:
Appendix IV: Comments from the Department of State:
Appendix V: Comments from the National Invasive Species Council
through the Department of the Interior:
Appendix VI: Comments from the Environmental Protection Agency:
Figures:
Figure 1: Profile of the Mute Swan:
Figure 2: Key Federal Departments and Their Responsibilities for
Invasive Species:
Figure 3: National Invasive Species Council and Management Plan:
Figure 4: Profile of the European Green Crab:
Figure 5: Profile of the Asian Long-Horned Beetle:
Figure 6: Profile of Buffelgrass:
Figure 7: Rates of Compliance with Ballast Water Exchange Requirement
for Ships Entering the Great Lakes, 1992-2001:
Figure 8: Discovery of Nonnative Aquatic Species Introduced into the
Great Lakes and Major Legislation and Regulatory Decisions, 1985-2002:
Figure 9: Profile of the Zebra Mussel:
Figure 10: Profile of West Nile Virus:
Abbreviations:
APHIS: Animal and Plant Health Inspection Service:
CDC: Centers for Disease Control:
EPA: Environmental Protection Agency:
FICMNEW: Federal Interagency Committee for the Management of Noxious
and Exotic Weeds:
GAO: General Accounting Office:
IMO: International Maritime Organization:
NANPCA: Nonindigenous Aquatic Nuisance Species Prevention and Control
Act:
NISA: National Invasive Species Act:
OMB: Office of Management and Budget:
OTA: Office of Technology Assessment:
USDA: United States Department of Agriculture:
USGS: U.S. Geological Survey:
Letter October 22, 2002:
The Honorable Ann M. Veneman
Secretary of Agriculture:
The Honorable Gale A. Norton
Secretary of the Interior:
The Honorable Donald L. Evans
Secretary of Commerce:
Invasive species--harmful, nonnative plants, animals, and
microorganisms--are found throughout the United States, causing
damage to crops, rangelands, waterways, and other ecosystems that is
estimated in the billions of dollars annually. Some have termed
invasive species “biological pollutants.” Unlike some chemical
pollutants that can degrade over time, biological pollutants have the
potential to persist, multiply, and spread.[Footnote 1] In addition to
their economic costs, invasive species can have a devastating effect on
natural areas, where they have strangled native plants, taken over
wetland habitats, crowded out native species, and deprived waterfowl
and other species of food sources. Conservation biologists rank
invasive species as the second most serious threat to endangered
species after habitat destruction. Overall, scientists, academicians,
and industry leaders are recognizing invasive species as one of the
most serious environmental threats of the twenty-first century. We have
issued two prior reports on this subject: one on funding to address
invasive species and the other on the government’s approach for quickly
responding to invasions by new species.[Footnote 2]
In February 1999, in response to the challenges faced by state and
federal agencies to minimize the spread of invasive species, President
Clinton issued Executive Order 13112. The order directs federal
agencies to take actions that will prevent the introduction of invasive
species; provide for their control; and minimize their impact on the
economy, the environment, and human health. The order established the
National Invasive Species Council, which now comprises the heads of 10
federal departments and agencies, to provide national leadership and
coordination in federal invasive species activities and to issue a
national invasive species management plan.[Footnote 3] The order also
directed the Secretary of the Interior to establish an advisory
committee to provide information and advice to the council.
The problem of invasive species is an international one. Organisms are
brought, intentionally or unintentionally, from one country to another.
They may also spread on their own across international borders. Because
of the international aspects of the issue, as well as the seriousness
of the problem for both Canada and the United States, we undertook a
review of federal invasive species management in cooperation with the
Office of the Auditor General of Canada. One issue of particular
importance to both countries is preventing aquatic invasive species
from entering the Great Lakes in the ballast water of ships.[Footnote
4] We and the Auditor General are issuing simultaneous but separate
reports. The Office of the Auditor General’s Report of the Commissioner
of the Environment and Sustainable Development to the House of Commons
contains a chapter on Canada’s invasive species management efforts.
The objectives of our review were to (1) assess the usefulness of
analyses that have estimated the economic impact of invasive species in
the United States to federal decision makers responsible for preventing
and controlling their spread; (2) assess the National Invasive Species
Management Plan, including the extent to which the plan has been
implemented; (3) provide the views of experts on the adequacy of
U.S. and Canadian federal government efforts to prevent the
introduction of invasive species into the Great Lakes via the ballast
water of ships; and (4) describe how the United States and Canada are
coordinating invasive species management efforts.
Among the efforts we undertook to analyze these issues was a survey
of all 32 members of the Invasive Species Advisory Committee. About
74 percent of the committee members responded to our survey and
68 percent completed it. We also observed meetings of the committee.
See appendix I for further details on our scope and methodology.
Results in Brief:
The scope of existing studies on the economic impact of invasive
species in the United States range from narrow to comprehensive, and
most are of limited use for guiding decision makers formulating federal
policies on prevention and control. Narrowly focused estimates include
analyses of past damages that are limited to a certain commercial
activities such as agricultural crop production and simple accountings
of the money spent to combat a particular invasive species. These
estimates typically do not examine economic damage done to natural
ecosystems, the expected costs and benefits of alternative control
measures, or the impact of possible invasions by other species in the
future. On the other hand, more comprehensive--and rare--analyses are
those that examine the past and prospective economic impact of invasive
species on commercial activities and natural ecosystems and the
potential costs of preventing or controlling them. In general, the more
comprehensive the approach used to assess the economic impacts of
invasive species, the greater its potential usefulness to
decision makers for identifying potential invasive species,
prioritizing their economic threat, and allocating resources to
minimize overall damages. Recent initiatives by federal agencies to
integrate information on the likelihood of invasion, the likelihood of
economic damage to commercial activities and natural ecosystems, and
the likely effectiveness of control methods should help support more
informed decisions about managing invasive species. However, according
to agency officials, efforts to produce more comprehensive and complex
studies that address the range of factors are hampered by a lack of
necessary data and of targeted resources.
The National Invasive Species Council’s 2001 management plan,
Meeting the Invasive Species Challenge, lacks a clear long-term outcome
and quantifiable measures of performance. While the actions called for
in the plan are likely to contribute to controlling invasive species,
it is unclear how implementing them will move the United States toward
a specific outcome, such as a lower number of new invasive species or
reduced spread of established species by a certain amount. Federal
officials recognize that there are deficiencies in the plan and are
working toward improvements. At present, the only available performance
measure that can be used to assess overall progress is the percentage
of planned actions that have been completed by the due dates set in the
plan. By this measure, implementation has been slow. As of September
2002, the departments and agencies composing the council had completed
less than 20 percent of the actions that the plan had called for by
that date, although they have begun work on others. A large majority of
the members of the Invasive Species Advisory Committee who responded to
our survey believe that the pace of implementation is inadequate. There
are numerous reasons for the slow progress, including delays in
establishing teams that will be responsible for guiding implementation
of the planned actions, the low priority given to implementation by the
council, and the lack of funding and staff responsible for doing the
work. Some stakeholders expressed the view that the low priority and
associated lack of progress may be due to the fact that the Congress
did not create the council or direct it to implement the plan. However,
even if the actions in the plan were more fully implemented their
effect would be uncertain because they typically do not call for
quantifiable improvements in invasive species management or control.
According to experts and agency officials we consulted, current efforts
by the United States and Canada are not adequate to prevent the
introduction of invasive species into the Great Lakes via the ballast
water of ships. Beginning in 1993, U.S. federal regulations required
ships that enter the Great Lakes from more than 200 nautical miles off
the U.S. coast to exchange their ballast water in the open ocean (that
is, in waters deeper than 2,000 meters and farther than 200
nautical miles from the U.S. coast), retain the ballast water on board,
or use an alternative, environmentally sound, method of ballast water
management. The purpose of the exchange is to flush the ballast tanks
of living organisms or kill them with salt water. Canada has had
voluntary guidelines calling for a similar ballast water exchange since
1989. The U.S. Coast Guard inspects all ships entering the Great Lakes
and, according to the agency, 88 percent of the ships entering with
ballast water from 1994 through 2001 had exchanged it in compliance
with U.S. regulations. The Coast Guard has not approved alternative
treatment methods; therefore, those that did not exchange their ballast
were prohibited from emptying their tanks while in the Great Lakes.
Nevertheless, aquatic invasive species are still entering the
Great Lakes and establishing themselves in the ecosystem. According to
the experts we consulted, at least two factors contribute to the
failure of the existing regulations to prevent introductions. First,
about 70 percent of the ships that enter the Great Lakes are classified
by the Coast Guard as having no ballast on board and are, therefore,
exempt from open-ocean exchange requirements. However, these ships may
in fact have thousands of gallons of residual ballast water and
sediment containing potentially invasive organisms in their drained
tanks that may be mixed with water later taken from, and then
discharged into, the Great Lakes. Second, for those ships that have
ballast, open-ocean exchange does not effectively remove or kill all
organisms in the ballast tanks. Although the United States and Canada
believe they should do more to protect the Great Lakes from ballast
water discharges, their plans for doing so depend on the development of
standards and technologies that will take a decade or more. In the
meantime, the continued introduction of invasive species could have
major economic and ecological consequences.
The United States and Canada participate in a wide variety of bilateral
and multilateral efforts to share information, conduct research, and
coordinate their efforts to reduce the threat of invasive species.
However, the two countries have not developed a comprehensive strategy
for joint prevention and management efforts. The long history of
coordination between the United States and Canada has focused on such
areas as agricultural research and shared boundary waters. There are
numerous bilateral and multilateral organizations of which the United
States and Canada are a part that recognize invasive species as an
important issue and provide a forum for increased planning and
coordination between the two countries. In general, however, efforts to
date have addressed specific pathways, species, or geographic areas in
a reactive way, rather than as part of a coordinated approach. The
National Invasive Species Council has recognized the need for the
United States to work with Canada (and Mexico) in a more comprehensive
manner and has taken initial steps to develop a North American
strategy, as called for by the national management plan. It is too
early to tell, however, what form such a strategy will take.
We are making several recommendations to the National Invasive Species
Council as a whole, and to the member departments and agencies
individually, aimed at improving the nation’s management of invasive
species. The council and member agencies generally agreed with these
recommendations.
Background:
Invasive Species Threaten the Economy and the Environment:
As we have reported in the past, the impact of invasive species in the
United States is widespread, and their consequences for the economy
and the environment are profound.[Footnote 5] They affect people’s
livelihoods and pose a significant risk to industries such as
agriculture, ranching, and fisheries. The cost to control invasive
species and the cost of damages they inflict, or could inflict, on
property or natural resources are estimated to total billions of
dollars annually. For example, according to the U.S. Department of
Agriculture (USDA), the Formosan termite causes at least $1 billion
annually in damages and control costs in 11 states (in 2001 dollars).
USDA also estimates that, if not managed, fruit flies could cause more
than $1.8 billion in damage each year (in 2001 dollars).
According to the National Invasive Species Council, hundreds, and
perhaps thousands, of nonnative species have established populations in
the United States. Invasive species continue to be introduced in new
locations, with recent examples including the northern snakehead fish
in Maryland and the emerald ash borer in Michigan. Many scientists
believe that invasive species are a significant threat to biodiversity
and are major or contributing causes of population declines for almost
half the endangered species in the United States. Invasive species can
alter entire ecosystems by disrupting food chains, preying on critical
native species such as pollinators, increasing the frequency of fires,
or--as in the case of some plants--simply overshadowing and smothering
native plants. Invasive species may arrive unintentionally as
contaminants of bulk commodities such as food, in packing materials and
shipping containers, or in ships’ ballast water. Others may be
introduced intentionally; kudzu, for example--a rapidly growing
invasive vine that thrives in the southeastern United States--was
intentionally introduced from Japan as an ornamental plant and was used
by USDA in the 1930s to control soil erosion. Other invasive species
are imported as crops, livestock, aquaculture species, or pets, and
later escape or are released into the environment. (See fig. 1 for
details on the mute swan, intentionally introduced to adorn parks and
private bird collections.):
Figure 1: Profile of the Mute Swan:
[See PDF for image]
[End of figure]
Not all nonnative species, however, cause harm. Many nonnative species,
such as cattle, wheat, soybeans, many fruits, and ornamental plants
(such as tulips and chrysanthemums), have been largely beneficial and
their propagation controllable. Various terms have been applied to
invasive species, including “alien,” “exotic,” “nonindigenous,” and
“nonnative.” In this report, we use the definition provided by
Executive Order 13112, which states that an invasive species is an
alien species whose introduction does or is likely to cause economic or
environmental harm or harm to human health. An alien species is one
that is not native to a particular ecosystem. (We used this definition,
as well as other factors, in selecting species to profile in
this report.):
The Federal Government Conducts a Variety of Invasive Species
Activities:
More than 20 federal agencies in 10 departments--including USDA,
Commerce, Defense, and the Interior--have responsibility for some
aspect of invasive species management. (See fig. 2.) States also have a
significant management role, but the extent of their involvement varies
considerably. USDA has the largest federal role because of its
responsibility to (1) conduct port-of-entry inspections and quarantine
goods coming into the country, (2) manage more than 190 million acres
of national forests and grasslands, (3) conduct research, and
(4) provide technical assistance to the private sector and in large
agricultural pest control projects. We reported that in fiscal
year 2000, seven of the departments obligated more than $624 million
for activities related to invasive species management.[Footnote 6]
According to the council, appropriations to those departments for such
activities increased in fiscal year 2001 to approximately
$1.05 billion, of which USDA received almost $975 million.
Figure 2: Key Federal Departments and Their Responsibilities for
Invasive Species:
[See PDF for image]
[End of figure]
In February 1999, invasive species prevention and control efforts
received heightened attention with the issuance of Executive
Order 13112. The executive order established the National Invasive
Species Council, which is now made up of the secretaries and
administrators of 10 federal departments and agencies.[Footnote 7] The
executive order required the Secretary of the Interior to establish an
advisory committee to provide information and advice to the council.
Accordingly, in November 1999, the secretary established the Invasive
Species Advisory Committee, composed of 32 nonfederal members
representing a range of interests relevant to invasive species,
including academia, environmental organizations, industry, trade
associations, Native American tribes, and state government.
The executive order also required that the council develop a national
invasive species management plan using a public process and revise it
biennially. Among other things, the executive order called for the plan
to (1) recommend performance-oriented goals and objectives and specific
measures of success, (2) recommend measures to minimize the risk of new
introductions of invasive species, and (3) review existing and
prospective approaches and authorities for preventing the introduction
and spread of invasive species. The council and its staff worked with
members of the advisory committee and other interested parties to
produce draft management plans for public comment. In January 2001, the
council issued the final plan, which identifies nine categories of
planned actions to aid in the prevention, control, and management of
invasive species in an effort to minimize their economic,
environmental, and human health impacts. (See fig. 3.) The council’s
plan calls for member departments to implement a total of 86 discrete
actions, each with an associated due date or start date. Examples of
the actions include establishing and coordinating long-and short-term
capacities for basic and applied research on invasive species and
gathering and disseminating information on the council’s Web site.
Figure 3: National Invasive Species Council and Management Plan:
[See PDF for image]
[End of figure]
The United States and Canada Face Many Difficult Issues Related to
Managing Invasive Species:
The United States and Canada have a mutual interest in limiting the
introduction or spread of invasive species across their borders. The
two countries share more than 5,500 miles of terrestrial and aquatic
border that provide potential pathways for invasive species. Each
country is the other’s largest trading partner, sending and receiving a
variety of goods, such as crops, livestock, wood, and horticultural
products, that can harbor invasive species. Therefore, species that
enter one of the two countries have opportunities to spread into
the other.
The Great Lakes--a shared U.S. and Canadian resource--have been subject
to invasion by nonnative species since the settlement of the region. At
least 160 nonnative aquatic organisms have become established in the
lakes since the 1800s, most of which have come from Europe, Asia, and
the Atlantic coast. More than one-third of the organisms have been
introduced in the past 30 years, a trend coinciding with the opening of
the St. Lawrence Seaway in 1959 and other changes in ship operations.
Ballast water in ships is considered a major pathway for the transfer
of invasive aquatic organisms to the Great Lakes. Ballast is essential
to the safe operation of ships because it enables them to maintain
their stability and control how high or low they ride in the water.
Ships take on or discharge ballast water over the course of a voyage to
counteract the loading or unloading of cargo, and in response to sea
conditions. The ballast that ships pump aboard in ports and harbors may
be fresh, brackish, or salt water. These waters may contain various
organisms that could then be carried to other ports around the world
where they might be discharged and survive.
Canada adopted voluntary ballast water management guidelines in 1989
in response to the 1988 discovery of nonnative zebra mussels in
Lake St. Clair. The Canadian guidelines were superceded by new
guidelines in 2000 and encourage ships’ masters entering the
Great Lakes and other waters under Canadian jurisdiction to employ
management practices--such as exchanging ballast water in the open
ocean--to minimize the probability of future introductions of harmful
aquatic organisms. They also direct ships’ masters to provide ballast
water
details to Canadian authorities.[Footnote 8] The United States followed
the
Canadian lead and passed the Nonindigenous Aquatic Nuisance Prevention
and
Control Act of 1990.[Footnote 9] This legislation directed the
Secretary of
Transportation to issue voluntary ballast water guidelines and
regulations for the Great Lakes. Joint United States and Canadian
voluntary guidelines, which closely tracked the 1989 Canadian
guidelines, went into effect in March 1991. The U.S. Coast Guard issued
the first set of mandatory ballast water regulations for the
Great Lakes in April 1993.[Footnote 10] The National Invasive Species
Act of 1996 amended the 1990 act and required the Secretary of
Transportation to issue voluntary ballast water guidelines for the rest
of the United States.
More Comprehensive Analysis of the Economic Impacts of Invasive Species
Would Better Inform Decision Makers:
The scope of existing analyses of the economic impact of invasive
species in the United States range from narrow to comprehensive.
Narrowly focused analyses include estimates of past damages that are
limited to commercial activities such as agricultural crop production
and simple accountings of the money spent to combat a particular
invasive species. These estimates typically do not include the economic
impact of these species on natural ecosystems, the expected costs and
benefits of alternative measures for preventing their entry or
controlling their spread, or the impacts of possible invasions by other
species in the future. On the other hand, more comprehensive--and rare-
-analyses are those that examine the past and prospective economic
impact of invasive species to both commercial activities and natural
ecosystems and the potential costs of preventing or controlling them.
Few analyses have been done that examine the likelihood that new
species will invade new locations and that estimate their costs.
Although the estimates we reviewed may have served the purpose for
which they were intended, the narrow scope of many of them may limit
their usefulness to decision makers formulating federal policies on
prevention and control. In general, the more comprehensive the approach
used to assess the economic impacts of invasive species, the more
likely its usefulness to decision makers for identifying potential
invasive species, prioritizing their economic threats, and allocating
resources to minimize overall damages. Federal agencies recognize the
value of this type of analysis and have recently taken steps to use it
more often. According to officials from several agencies, however,
efforts to improve economic impact analyses are hampered by a lack of
data on invasive species and a lack of economists assigned to assessing
their economic impacts on commercial activities and natural ecosystems.
The Narrow Scope of Many Analyses May Limit Their Usefulness to
Decision Makers:
The narrow scope of many analyses of the economic impacts of invasive
species may limit their usefulness to decision makers developing
policies and allocating resources to address the problem.[Footnote 11]
First, many of the analyses we reviewed do not address the economic
impact of invasive species on natural area ecosystems. Instead, they
reflect the impacts of invasive species on commercial activities such
as agricultural and timber production and fisheries. This reflects the
fact that most of the management and control of invasive species in the
United States has focused on those species that damage agricultural
crops and livestock. For example, the Federal Interagency Committee for
the Management of Noxious and Exotic Weeds (FICMNEW) studied the
economic impact of weeds on the U.S. economy and found the estimated
value of losses from invasive weed species to be about $15 billion per
year.[Footnote 12], [Footnote 13] However, the committee reported that
the economic impact on most nonagricultural sites was not available.
Focusing solely on the impact of invasive species on commercially
valuable activities ignores the potential impact of invasive species on
ecosystems as a whole, possibly understating the impact of these
species.
[Footnote 14] Consistent with that point, according to the
Environmental
Protection Agency, the true cost of invasive species is underestimated
if
estimates of damages do not include lost ecosystem services, such as
water
purification and aesthetic values.[Footnote 15]
Second, many of the existing analyses do not fully account for the
expected costs and benefits that are associated with different control
methods for invasive species. Two frequently cited summations of the
aggregate impacts of invasive species in the United States were based
on estimates of this type. The first, by the U.S. Office of Technology
Assessment (OTA), estimated that by 1991 at least 4,500 nonnative
species had become established in the United States, of which about 600
had caused severe harm. The OTA was able to obtain data showing that
the economic impact of 79 of these species totaled about $118 billion
between 1906 and 1991 and impact included damage to agricultural crops,
industrial activities, and human health.[Footnote 16] The second effort
was by researchers at Cornell University who estimated in 1999 that
approximately 50,000 nonnative plant and animal species are known to
have entered the United States--although not all have established
harmful populations--and that the overall cost of the harmful species
is about $137 billion annually.[Footnote 17] However, the estimates
that these aggregate studies relied on typically did not include an
analysis of whether control measures are desirable given their costs or
what the most cost-effective methods for preventing or controlling
particular invasive species would be. (Many of the estimates included
in these aggregate studies also lack information on the impact of
invasive species on natural area ecosystems.):
It is not unusual for analyses to lack information for the assessment
of the cost-effectiveness of prevention and control measures. The most
complete data on invasive species damages, and prevention and control
costs and effectiveness are available for known pests that the USDA has
identified as serious threats to agriculture on the basis of past
invasions. These include diseases and pests such as the virus that
causes foot-and-mouth disease, citrus canker, and the Mediterranean
fruit fly. Yet, even for these pests, relatively little is known about
the likely success of alternative methods for preventing their entry or
controlling their spread. For example, an official in charge of risk
analysis for USDA’s Animal and Plant Health Inspection Service (APHIS)
told us that there is a general lack of information on the likely
success of different measures--short of outright bans on the
importation of some products--that could be used to prevent the
importation of invasive species into the country. He said that even for
a pest such as the one that causes foot-and-mouth disease, for which
the potential costs of an outbreak have been studied, data are not
available on the cost-effectiveness of many prevention methods.
Prevention methods could range from a ban of all products that might
carry the disease from all countries known to harbor it to less
stringent restrictions that allow more trade but that might provide
less protection. For invasive species that have previously entered the
United States and caused damages, there is also little information
available on the likelihood that they will do so again at particular
times and by particular pathways. Even less information of this nature
is available for non-agricultural pests. More comprehensive analyses
that include such information may help decision makers allocate limited
resources among different prevention and control efforts.
A third way in which the narrow scope of many estimates may limit their
usefulness is that they focus on the impact of species that are known
to cause problems but do not provide decision makers with information
on the likelihood that new species will invade and cause damage. The
typical estimate includes data on the damages already caused by species
or the money spent to control them. The OTA and Cornell estimates
mentioned above are largely based on these types of estimates. Other
examples include USDA’s report that it cost about $26 million between
1996 and 2000 to remove trees infested with Asian long-horned beetle in
New York and:
Illinois[Footnote 18] and the estimate by North Dakota State University
researchers in 1996 that three species of knapweed cause about
$48 million per year in damage to Montana’s economy.[Footnote 19] Data
such as these can be used to estimate the continued effects of a
species in the same location or the potential effects in a new
location. For example, researchers used data on the effects that the
European green crab had had on East Coast fisheries to estimate that
this invasive species could damage native oyster, clam and crab
fisheries on the West Coast by as much as $54 million per
year.[Footnote 20] (See fig. 4 for more information on the European
green crab.):
However, experts in biological invasions caution that it is difficult
to extrapolate from a past invasion event to introductions of new
species that have not occurred. According to an official with the
Department of the Interior, decision makers need guidance on which
potential invasive species pose the greatest threat to the United
States and how to best design policies for combating them. Some
researchers suggest that the best way of protecting ourselves from
invasive species is to try to predict new arrivals of potentially
invasive species, study the basic biology of probable new arrivals, and
work on biological controls for them as part of a program for early
detection and rapid response.[Footnote 21] One environmental scientist
has suggested that one of the best ways to predict the introduction of
and damage from species new to the United States is to study recent
introductions of species into other countries that have ecosystems
similar to those in this country.[Footnote 22] While USDA and others
have done some studies of this type, particularly for agricultural
pests, the preponderance of economic analysis has focused on species
that have already invaded the United States rather than on new species
that could invade in the future.
Figure 4: Profile of the European Green Crab:
[See PDF for image]
[End of figure]
More Comprehensive Analyses Are Potentially More Useful to
Decision Makers:
While most of the analyses that we reviewed have limitations in their
scope that lessen their usefulness to decision makers, some used a more
comprehensive approach. Some analyses accounted more fully for the
expected costs and benefits to producers and consumers of different
control measures. For example, to further improve analysis of the
expected costs and benefits of control measures, the Risk Assessment
and Management Committee under the Aquatic Nuisance Species Task Force
expanded the scope of existing federal risk assessment processes and
methodologies to include the socioeconomic impacts of invasive
species.[Footnote 23] In a case study covering, in part, the effects of
importing the Asian black carp, U.S. Geological Survey (USGS)
researchers balanced the potential for economic gains from
intentionally introducing this species--it eats snails that may harbor
parasites in fishponds and zebra mussels in the wild--against the
potential for economic and environmental damage if it became
established in the wild.[Footnote 24] Risks were estimated by expert
judgment. Based upon the outcome of the assessment, the Aquatic
Nuisance Species Task Force decided that establishment of this species
would create an unacceptable level of potential harm. The U.S. Fish and
Wildlife Service has proposed amending its regulations to add the Asian
black carp to a list of injurious fish, crustacean, and mollusk species
that are not allowed to be imported into the United States.[Footnote
25]
Researchers also recently discussed how the benefits from integrating
risk assessment and benefit cost analysis into the regulatory process
can provide decision makers with more information than is available
when only a single dimension of information is considered. These two
dimensions of information give decision makers an opportunity to
evaluate the tradeoffs that they face when they choose among
alternative
regulatory measures.[Footnote 26] The researchers addressed the
question of
the tradeoff between banning the imports of commodities that may harbor
invasive species and enjoying the benefits of those commodities. As an
example, they analyzed a partial ban on imports of Mexican avocados and
found that, based on the assessment of invasion risk alone, the ban
seemed to have greater benefits than costs.[Footnote 27] However, when
they incorporated into their analysis the costs to U.S. consumers that
the ban would impose in terms of reduced availability of low-cost
avocados, they found that less stringent regulations would likely be
more desirable than the ban.
As another example, the same researchers demonstrated the benefit of
integrating benefit cost analysis and risk assessment simultaneously
into the evaluation of risk management options for the invasive fungus
that causes Karnal bunt disease in wheat. In this case, they
illustrated how analyses that estimate invasion risks and costs and
benefits for control programs for this species but do not adjust
benefit estimates of the control program components for risk may not
help decision makers choose control policies with the greatest overall
benefit. USDA had estimated that the Karnal bunt fungus could cause
more than $500 million per year in damages to the U.S. wheat industry
by reducing the amount of wheat suitable for export and had adopted a
program to control the spread of the fungus.[Footnote 28] However,
researchers found that the USDA’s estimate was incomplete, in part
because it focused on reducing the probability of an outbreak of the
disease by adopting multiple quarantine options but did not examine
whether each option was an economically efficient quarantine policy.
When the researchers examined these options individually, they were
able to identify the most efficient options, that is, those imposing
the least cost on producers. According to these researchers, by not
adopting only the most efficient options, the costs of the agency’s
program for controlling the spread of the fungus exceeded the program’s
benefit. The researchers suggest that failure to look at the expected
marginal benefits and costs of various quarantine options may have led
to the adoption of an unnecessarily costly quarantine policy.
Another way in which some estimates have been more comprehensive is by
including an examination of the impact of invasive species on more than
just commercial commodities. For example, in estimating the effect of
gypsy moth caterpillars on forest trees, researchers estimated that
benefits from programs that would slow their spread would be between
$1 billion and $4.8 billion in present value, depending on their rate
of spread and the control programs adopted, in increased timber
production, recreational opportunities, residential and scenic land
values, water quality and other amenities, over 25 years.[Footnote 29]
In another example, researchers used an economic model based on
property values to estimate damages to lakefront properties in New
Hampshire from milfoil, an invasive aquatic weed that causes serious
economic, recreational, and ecological damage. Their estimates showed
that between 1990 and 1995, property values on milfoil-infested lakes
were about 16 percent lower than similar properties on uninfested
lakes.[Footnote 30] According to an official with the Department of
Commerce, the state of New Hampshire adopted a program to control this
invasive weed on the basis of this study.
Finally, some analysts are taking more comprehensive approaches
by analyzing the likelihood that species will be introduced, become
established, and cause harm in particular geographic areas or via
particular pathways. For example, a researcher has built upon earlier
USDA work on pest risk assessment to evaluate the likelihood of
establishment of Eurasian poplar leaf rust.[Footnote 31] The researcher
combined information on the incidence of the disease and the location
of susceptible plant hosts in the United States with data on past
invasions of this species in similar ecosystems abroad, to assess the
likely danger to geographic areas in the United States.
In another example, USDA examined the likelihood that the Eurasian
pine shoot beetle would enter and spread via various pathways and which
pathways would impose the greatest risk of harm.[Footnote 32] This
beetle emerged as a new and potentially serious pest of timber in the
upper midwestern United States in 1992. Potential losses from the
beetle were large, and the state of Michigan proposed 25 mitigation
measures that would have included large expenditures on pesticide
sprays. USDA’s analysis, which included a risk assessment of the likely
pathways by which the beetle might spread, showed that 99.8 percent of
the risk of spread occurred by one pathway in a 2-week period during
the timber’s processing. Using this information, the timber industry
took appropriate control measures during this 2-week period to
effectively manage the risk at low cost and without the need
for regulation.
Recent Actions May Prompt More Comprehensive Analyses:
Recent federal actions may help to prompt further improvements in the
economic impact analysis available to decision makers. Among other
things, Executive Order 13112 calls on federal agencies to prevent the
introduction of invasive species, and to detect, respond rapidly to,
and control them in a cost-effective and environmentally sound manner.
The executive order also directs agencies to determine that the
benefits of any actions they take that are likely to cause or promote
the introduction or spread of invasive species clearly outweigh the
potential harm caused by the species and to take measures to minimize
the risk of harm in conjunction with these actions. Implementing the
order will thus require agencies to undertake more comprehensive
studies of risks, costs, and benefits.
In addition, the federal Aquatic Nuisance Species Task Force has
developed a process to evaluate the risk of introducing nonnative
organisms into a new environment and, if needed, determine the correct:
management steps to mitigate that risk.[Footnote 33] The task force has
also developed guidelines to provide direction to assist states in the
development of their own management plans for aquatic nuisance
species.[Footnote 34] The guidance, formally adopted by the task force
in 2000, emphasizes a need for feasible, cost-effective, comprehensive
plans that can be developed quickly, and can be used to focus on the
most pressing species problems that can be effectively managed. As an
example of how these efforts have been used, the U.S. Fish and Wildlife
Service, USDA’s Animal and Plant Health Inspection Service, and the
National Oceanic and Atmospheric Administration, in conjunction with
state authorities, have prevented the spread of the aquatic weed
caulerpa in U.S. coastal waters.[Footnote 35]
USDA has also taken recent steps to refine its risk assessment
practices. Over the years, in making decisions about allowing the
importation of certain agricultural commodities from countries known to
harbor potentially serious plant pests, USDA occasionally used analysis
that led to partial rather than outright bans of those commodities in
recognition of both risks of invasion and the benefits that consumers
would obtain from access to that commodity.[Footnote 36] An impetus for
doing more of this type of analysis was international trade agreements
that
call for the United States and others to use the least restrictive
measures
to protect against invasive pests. In other words, the trade agreements
prohibit countries from imposing outright bans of certain agricultural
commodities if biological and economic data show that partial bans
would be just as effective. Partly in response to these agreements,
USDA’s Animal and Plant Health Inspection Service issued for the first
time in August 2001 guidelines for the agency to use when assessing the
risks posed by diseases and pests.[Footnote 37] These guidelines state
that risk assessments should consider the probable biological and
economic consequences of the entry and establishment of invasive
species, as well as the likelihood that those species will enter.
However, according to the chief of APHIS Risk Assessment Systems,
agency assessments done in the past frequently focused on the
likelihood that species will enter and become established and, because
of a lack of credible data, were less focused on their biological and
economic consequences.
Moreover, USDA recently established a task team to improve the ways in
which risk assessment is incorporated into the department’s analyses of
the economic impacts of invasive species. Agency officials said that
this effort would better enable federal decision makers to adhere to
Executive Order 13112’s emphasis on a risk-based approach to dealing
with invasive species. In addition, the officials said that the
information generated by the task team would also help the National
Invasive Species Council implement the national management plan, which
calls for a risk-based approach to preventing potential invasive
species from becoming established.[Footnote 38]
Officials from the National Invasive Species Council staff and
departments within the council agreed that improved economic analysis
would help the federal government develop an overall budget for
invasive species programs. However, they cautioned that the capacity of
the federal government to do this work is limited. Specifically, there
are limits to the data available on the biology of invasive species and
the impacts they have--particularly on natural ecosystems--and the
effectiveness of control methods. The officials also stated that there
are not enough resources devoted to analyzing the impacts of
invasive species.
The National Management Plan Lacks a Clear Long-Term Outcome, and Its
Implementation Has Been Slow:
While the National Invasive Species Council’s 2001 management plan,
Meeting the Invasive Species Challenge, calls for actions that are
likely to help control invasive species, it lacks a clear long-term
outcome and quantifiable performance criteria against which to evaluate
the overall success of the plan. Federal officials recognize that there
are deficiencies in the plan and are working toward improving it. At
present, however, the only available performance measure that can be
used to assess overall progress is the percentage of planned actions
that have been completed by the due dates set in the plan. By this
measure, implementation has been slow. Specifically, the council
departments have completed less than 20 percent of the planned actions
that were called for by September 2002, although they have begun work
on others. A large majority of the members of the invasive species
advisory committee who responded to our survey believe that the pace of
implementation is inadequate. In addition, some of the actions that
agencies have reported to the council are not clearly linked to
coordinated implementation of the management plan. Our survey and other
evidence indicate numerous reasons for the slow progress, including
delays in establishing implementation teams that will be responsible
for carrying out the planned actions, the low priority given to
implementation by the council, and the lack of funding and shortage of
staff responsible for doing the work. Another factor contributing to
slow progress was the need to transition to a new administration.
However, while the national management plan calls for many actions that
would likely contribute to preventing and controlling invasive species,
even if the actions in the plan were more fully implemented their
effect would be uncertain because they typically do not call for
quantifiable improvements in invasive species management or control.
National Invasive Species Management Plan Does Not Clearly Define a
Long-Term Outcome or Contain Performance Measures:
The national management plan does not clearly define a long-term
outcome or measures of success as are called for by sound management
principles. The executive order states that the management plan shall
“detail and recommend performance-oriented goals and objectives and
specific measures of success for federal agency efforts concerning
invasive species.” Consistent with that requirement, the council and
its advisory committee adopted as one of their guiding principles that
efforts to manage invasive species are most effective when they have
goals and objectives that are clearly defined and prioritized. Both the
executive order and this guiding principle are also consistent with the
Government Performance and Results Act of 1993, which emphasizes
setting measurable goals and holding agencies accountable by evaluating
performance against those goals.[Footnote 39]
However, the council did not articulate in the plan a long-term outcome
or condition toward which the federal government should strive. For
example, the plan does not contain overall performance-oriented goals
and objectives, such as reducing the introduction of new species by a
certain percentage or halting the spread of established species on
public lands. Instead, the plan contains an extensive list of actions
that, while likely to contribute to preventing and controlling invasive
species, are not clearly part of a comprehensive strategy.
Similarly, many of the actions in the plan call for the federal
departments to take certain steps rather than achieve specific results
and do not have measurable outcomes. For example, the plan calls for
the council, starting in January 2001, to work with relevant
organizations to “expand opportunities to share information,
technologies, and technical capacity on the control and management of
invasive species with other countries.” Another action item calls for
the council to have outlined by June 2001 a plan for a campaign to
encourage U.S. travelers to voluntarily reduce the risk of spreading
invasive species overseas. Other actions call for the council to
support international conferences and seminars. We believe that these
types of actions are more process-oriented than outcome-oriented. Taken
individually, the actions may be useful, but it will be difficult to
judge whether or not they are successful and have contributed to an
overall goal.
Respondents to our survey also raised concerns about the lack of
measurability in the plan. While the majority of respondents (17 of 23)
said that the plan is focused on the most important issues, 9
criticized it for a lack of specificity or a clear mechanism for
measuring effectiveness or holding departments accountable for
implementing it. Of these, several commented that it is unclear how we
will know when actions are implemented and completed. Others noted that
there are no consequences for the council, staff, or agencies if they
miss deadlines. Other stakeholders made similar comments to us. For
example, one person who was involved in the development of the
management plan told us that it represents a “fundamentally misguided
approach” and that it contains no coherent goal or measures of success.
He said that the plan should have measures of success such as a
reduction in the rate of introduction or spread of species. Another
stakeholder said that the plan is unclear with regard to what actions
would be enough to help solve the problem and echoed concerns about the
difficulty measuring success. Eight respondents to our survey, however,
made more positive comments about the degree of specificity in the
plan, stating that the plan was clear, measurable, and achievable and
that it had very specific actions with deadlines for agencies
to implement.
The council acknowledged in the plan itself that many of the details
of the actions called for would require further development in the
implementation phase. The Department of the Interior’s Deputy Assistant
Secretary for Performance and Management told us that the plan was
developed with little input from people trained in performance
management processes. In addition, the Executive Director of the
council staff told us that, in her opinion, given the scope of this
first-time effort, it would have been unrealistic and difficult to also
agree on specific measurable goals. She also said that in many areas,
the federal government does not have the data on invasive species
conditions needed to set long-term goals and develop better performance
measures. She said that many of the actions called for in the
management plan are designed to help develop needed data. In their
comments on our draft report, EPA and the Department of the Interior
also noted that it would be difficult to apply performance measures to
invasive species management activities.
The executive order calls for the council to revise the plan by January
2003. However, the Executive Director of the council told us that the
council and the advisory committee had agreed not to begin revising the
management plan until after the council prepares a progress report on
the plan. That report is also due to the Office of Management and
Budget (OMB) in January 2003.
The council is in the process of working with OMB on implementing one
of the planned actions that should help to establish a desired outcome
and relevant performance measures. The plan called for a crosscut
budget proposal for federal agency expenditures concerning invasive
species beginning in fiscal year 2003. The council and OMB are hoping
to have a proposal ready for the fiscal year 2004 budget cycle.
According to the Department of the Interior official responsible for
this project on behalf of the council, the proposal will represent the
beginnings of a strategic plan for the federal government’s invasive
species activities. It will be performance-oriented with common long-
term goals, intermediate goals, and definitions for the relevant
departments. OMB will identify performance measures with help from a
task team of federal stakeholders and will initially focus on early
detection and rapid response, control, and prevention. According to the
council, the proposal for fiscal year 2004 will not represent the
totality of invasive species expenditures or efforts but will primarily
focus on the activities of the Departments of the Interior,
Agriculture, and Commerce.
National Invasive Species Council Departments Have Completed a
Small Percentage of Actions in the Management Plan:
While the council has not reported on implementation of the plan, we
estimate that, as of September 2002, council departments had completed
less than 20 percent of the actions that the plan had called for by
that date. The departments have started work on other planned actions,
including some that have a deadline after September 2002 and that the
council believes are a high priority. When asked to assess
implementation of the plan, 18 of the 21 advisory committee members who
responded to that question said that the council was making inadequate
or very inadequate progress. Survey comments and other evidence
indicate various reasons for the lack of progress. Delays in
implementing the plan will hamper agency efforts to prevent and control
invasive species as intended by the executive order.
Lack of Departmental Reporting Hinders Measurement of Progress:
It has been difficult to quantitatively measure the council’s progress
in implementing the management plan because only 6 of the 10 member
departments had submitted reports summarizing the steps they had taken
to implement the plan. The plan calls for departments to submit such
reports annually beginning in October 2001. Council staff aggregated
the reports that were submitted into one summary of activities. These
annual reports would be used to carry out yet another requirement of
the executive order and management plan that calls for the council to
revise the plan by January 2003.
Several survey respondents commented that it was difficult for them to
evaluate the council’s progress in implementing the plan because
information from the council had been inadequate. For example, some
respondents wrote that the level of interaction between them and the
council was not sufficient, and that feedback to the advisory committee
from the council on implementation progress has been poor.
The management plan also calls for the council to establish a
“transparent oversight mechanism” that engages public involvement. The
purpose of the oversight mechanism would be for use by federal agencies
in complying with the executive order and reporting on its
implementation, which includes the management plan. The plan called for
the mechanism to be in place by April 2001, but according to the
council staff, work has not yet begun.
The Council Has Completed Less Than 20 Percent of Planned Actions:
Our review of the council’s summary of department actions, which
focused on the 65 planned actions with due dates through September 2002
(an additional 21 planned actions have due dates after September 2002,
for a total of 86), revealed that less than 20 percent of the actions
due by September 2002 were complete.[Footnote 40] Several actions
completed on time related to the development of the council’s Web site,
which is found at www.invasivespecies.gov. Another completed action
concerned a series of regional workshops on invasive species for
policymakers that the council, led by the Department of State, cohosted
with countries such as Brazil, Costa Rica, Denmark, Thailand, and
Zambia. Also in accord with the plan, the National Oceanic and
Atmospheric Administration, the Coast Guard, the Department of the
Interior, and EPA have sponsored research related to ballast
water management.
Departments and the council staff have also started work on over
60 percent of the other planned actions, including some that have a due
date beyond September 2002. For example, departmental representatives
and the council staff are working with the President’s Council on
Environmental Quality on guidance to federal agencies on how to
consider the issue of invasive species as they prepare analyses
required by the National Environmental Policy Act. However, the
guidance is not expected to be ready until early 2003, past its
August 2001 target date. USDA has begun work on additional regulations
to further reduce the risk of species introductions via solid wood
packing materials, but the department did not meet the management
plan’s January 2002 deadline. (See fig. 5 for information on the Asian
long-horned beetle, an invasive species that entered the United States
in solid wood packing material.) Council departments have begun work on
a national public awareness campaign--cataloging existing public
awareness programs and conducting a survey of public attitudes toward
invasive species--and are seeking budget approval for starting the
campaign in fiscal year 2004. They missed the June 2002 completion date
called for in the plan. Among those actions that the council is working
on that are not due until after September 2002 is a risk-based
comprehensive screening system for evaluating first-time intentionally
introduced nonnative species, which is due by December 2003. According
to council staff, the complexities of implementing a screening system
dictate that the departments work on this now. According to council
staff, work is also underway on a coordinated rapid response program
due by July 2003.
Figure 5: Profile of the Asian Long-Horned Beetle:
[See PDF for image]
[End of figure]
There are also actions in the plan that the council has not started to
work on. For example, the council has not acted on the item in the plan
that called for draft legislation by January 2002 to authorize tax
incentives and otherwise encourage participation of private landowners
in restoration programs. Nor has the council moved to ensure that a
clearly defined process and procedures be in place by July 2001 to help
resolve jurisdictional and other disputes regarding invasive species
issues. Two respondents to our survey commented on the lack of council
progress toward a resolution process, citing the need for it in cases
such as one where federal agencies are taking contradictory actions
with respect to an invasive rangeland grass (see fig. 6 for more on
buffelgrass). In its comments on our draft report, EPA emphasized the
significance of this deficiency and noted that there are other
situations where a resolution process is needed, such as fish stocking
to enhance recreational fisheries and using genetically modified
organisms in aquaculture and agriculture.
Figure 6: Profile of Buffelgrass:
[See PDF for image]
[End of figure]
The majority of the advisory committee members responding to our survey
noted the lack of progress made by the council agencies. Eighteen of
the 21 members who responded to a question about implementation said
that that the council was making inadequate or very inadequate
progress. One noted that the only clear achievement to date is the
council’s Web site.
Some of the Agencies’ Actions Are Not Clearly Linked to Coordinated
Implementation of the Management Plan:
In our view, while it is apparent that the agencies are taking various
actions to address invasive species issues, the actions the agencies
have reported to the council often do not represent coordinated
progress toward implementation of the plan or management of the
problem. The executive order and the management plan both emphasized
the need for coordination among agencies. As evidence of that emphasis,
a majority of the actions in the management plan are to be carried out
by multiple agencies. However, the actions that the agencies reported
to the council often did not appear to be directly linked to each other
or be directly responsive to the specific actions called for by the
management plan. In our survey, several advisory committee members also
commented that coordination has been inadequate.
For example, the management plan called for the council to implement by
January 2002 a process for identifying high-priority invasive species
that are likely to be introduced unintentionally and for which
effective mitigation tools are necessary. One agency noted to the
council that it had contracted with professional societies to provide a
list of the most harmful insect, weed, and disease plant pests that are
not yet present in the country or present but not widely distributed.
It also noted that it has a risk assessment procedure for identifying
pests that may be introduced with commodities such as agricultural
products. A second agency noted that it had held a workshop to identify
potentially invasive species that might enter the nation’s waters from
Eastern Europe. A third agency indicated that it is providing training
for firefighters to reduce the spread of weeds from one fire site to
another. While these activities are related to the planned action, they
do not indicate that the agencies are working together through the
council to implement a process for identifying high priority species as
called for by the plan.
The Executive Director of the council acknowledged that some of the
actions reported by agencies did not seem to directly link to the
management plan, although such information was useful for overall
coordination purposes. She said that in the future implementation teams
would help the agencies focus on those actions that are directly linked
to the management plan. The Executive Director and one of the Assistant
Directors of the council told us that they believe that increased
coordination has been an important accomplishment and that agency
officials are now routinely talking with each other about invasive
species management issues. In comments on our draft report, the
Department of the Interior also noted that coordination and
communication among the agencies has increased.
Slow Progress on Management Plan Is Due to a Combination of Factors:
Our survey and other evidence indicate that the slow progress in
implementing the management plan has been caused by a combination of
factors, including delays in forming teams responsible for developing
specific implementation plans, the lack of priority given to the plan
by the council as a whole and by the departments individually, and
insufficient funding specifically targeted to support the plan.
Progress was also slowed by the need to transition from the previous
administration to the current administration.
Delays Forming Implementation Teams:
In October 2000, before issuing the management plan, the advisory
committee and council staff agreed that implementation teams made up of
federal and nonfederal stakeholders were needed to put the management
plan into action. The advisory committee members and council staff
agreed that the teams should be under the auspices of the advisory
committee and be closely aligned to the major sections of the
management plan. Specifically, the teams would be responsible for
“delivery” of the planned actions. For example, a prevention team would
be responsible for guiding implementation of the actions relevant to
prevention. However, for various reasons, most implementation teams
were not formed until June 2002. Specifically:
* The Executive Director of the council told us that she did not
believe it would have been appropriate to form the implementation teams
until after the management plan was issued in January 2001.
* The change in administration then delayed action on implementing the
plan by about 6 months because it took time for cabinet secretaries--
the members of the council--and other political appointees to be
nominated and confirmed; departments were ready to move forward with
forming the implementation teams in the fall of 2001.
* By that time, the first term of all of the advisory committee members
was approaching its end in November 2001 and because the advisory
committee members were to be an integral part of the implementation
teams, the Executive Director told us it did not make sense to form the
teams until the next advisory committee was convened.
* Appointment of the second set of advisory committee members was
delayed until April 2002 for a number of reasons, including the
temporary loss of e-mail and regular mail delivery at the Department of
the Interior.[Footnote 41]
* The second advisory committee held its first meeting in May 2002, and
committee members and council staff decided that the implementation
teams should not meet until after the advisory committee members had a
chance to review the teams’ responsibilities and membership and discuss
them at greater length at their next scheduled meeting in June 2002.
* In June 2002, nine implementation teams were created that largely
mirror sections of the management plan (all but two of the teams will
comprise federal and nonfederal members).
The Executive Director of the council told us the decision to create
implementation teams of federal and nonfederal members under the
auspices of the advisory committee was in part in recognition of the
importance of getting consensus from key stakeholders early in the
implementation process. She told us that she recognizes that there are
potential problems with the teams comprising a disparate group of
federal and nonfederal stakeholders. Specifically, logistical problems
in getting the teams together and disputes within the teams could delay
the federal departments in taking action to implement the plan. She
said that the council would have to monitor the teams closely to
determine whether or not they are effective.
The delay in establishing the implementation teams has hindered the
agencies in achieving an important objective of both the executive
order and the management plan--coordinated action. Several respondents
to our survey commented that they had not seen adequate increases in
the amount of coordination, and some pointed to the delays in forming
the teams as a cause. One respondent thought that federal departments
and agencies were continuing to pursue their own mandates and programs
with only a cursory regard for the framework and coordination that the
council attempts to provide. The Executive Director of the council told
us that she expected coordination to improve as the implementation
teams become established.
In our view, the relationship of the advisory committee to the
implementation teams has slowed progress on the plan and could continue
to do so. While we understand why the council decided to form the
implementation teams under the auspices of the advisory committee--to
foster consensus among key stakeholders early in the implementation
process--we believe that this decision may slow federal action.
Specifically, it may be difficult for teams of federal and nonfederal
stakeholders to put forth the concerted effort needed to implement the
management plan. We are also concerned that it will be difficult to
hold the departments accountable for carrying out the plan if they are
relying upon the actions of teams with federal and nonfederal members.
Lack of Priority from the Council and Its Member Departments:
About one-half of the respondents to our survey criticized the council
and the departments for not giving the plan a higher priority. For
example, several noted that it did not appear that the council had
positioned itself to take a leadership role in implementing the plan or
that the plan was not a high priority on the agendas of the leaders of
the council’s member departments. In addition, numerous survey
respondents said that the individual departments needed to give the
plan higher priority by providing better support in staff
and resources.
Our review of agencies’ performance plans (prepared pursuant to the
Government Performance and Results Act) also indicates that
implementing the management plan is not a high priority for individual
agencies. We reviewed the performance plans of the three cochair
departments on the council (the departments of Agriculture, Commerce,
and the Interior), as well as those of the Department of
Transportation, the Environmental Protection Agency, and agencies
within the Department of the Interior (National Park Service, Bureau of
Land Management, Fish and Wildlife Service, and Geological Survey).
While most of the agencies’ performance plans describe activities
intended to control or manage invasive species--and are therefore
consistent with the national management plan--none of the plans
specifically identified as a measure of performance implementing
actions called for by the council’s plan. As one official from the
Environmental Protection Agency told us, activities that are not in the
agency’s performance plan do not receive a high priority. Nevertheless,
the Department of the Interior official responsible for pulling
together the crosscut budget for invasive species programs told us that
he believes that process--because of its emphasis on performance
measures--will help departments link the management plan to their
performance plans.
With regard to the notion that the council was not giving the plan a
high priority, three of the 23 advisory committee members who responded
to our survey commented on the absence of specific legislative
authority establishing the council. One stated “the council needs to be
approved legislatively so that they are their own entity with better
options to act.” Another said “Congress or the President needs to make
this a priority through legislation or funding. . . . Agencies need to
be told this is a priority and given funding to accomplish their
goals.” Because executive orders such as the one that established the
council do not provide any additional authority to agencies, the
Executive Director of the council noted that legislative authority for
the council, depending on how it was structured, could be useful in
implementing the management plan. Officials from USDA, the Department
of Defense, and EPA who are departmental liaisons to the council also
told us that legislative authority, if properly written, would make it
easier for council departments to implement the management plan. The
Congress has recently considered legislation that would give the
council certain responsibilities; namely to provide input into
decisions about allocating funds to local governments and other
organizations for controlling invasive plants. However, the Executive
Director of the council told us that such a requirement would be
unworkable if the legislation did not also formally establish the
council and a future administration decided to discontinue the
executive order that created the council.
The management plan calls for the council to conduct an evaluation by
January 2002 of the current legal authorities relevant to invasive
species. The council has not completed the evaluation. According to the
plan, the evaluation is to include an analysis of whether and how
existing authorities may be better utilized and could be used to
develop recommendations for changes in legal authority. However, it
does not state that the analysis should address whether the council
itself is hampered in its mission by not having specific legislative
authority that would allow it to direct its members to implement the
national management plan.
Insufficient Funding and Staff:
In the management plan, the council stated that many of the actions
could be completed or at least initiated with current resources but
that without significant additional resources for existing and new
programs it would not be possible to accomplish the goals of the plan
within the specified timeframes. The council also noted in its comments
on the draft report that it believes the timeframes in the plan are
optimistic given current resources. Two of the actions in the plan
called for federal agencies to request additional funding for separate
management functions through the annual appropriations process
beginning in fiscal year 2003. According to a summary prepared by the
council, the President’s budget request for invasive species activities
in fiscal year 2003 was at least 23 percent more than was requested in
fiscal year 2002 (although slightly less than Congress appropriated in
fiscal year 2002).[Footnote 42] The council went on to say in the plan
that estimates of the additional support required would depend on the
details of implementation schedules developed by federal agencies and
stakeholders. As we described above, however, the council and the
advisory committee have only recently created the teams that will be
responsible for working out the detailed plans for implementation.
Therefore, it is unclear what additional resources are needed and
whether the requested appropriations will be adequate to implement
the plan.
In response to several of the questions in our survey, advisory
committee members cited the lack of funding as a key reason for
poor implementation of the council’s management plan. (We did not
independently assess the adequacy of funding.) Of the 18 who said that
the council was inadequately implementing the plan, 9 said that funding
was insufficient. A typical comment was that the council members need
to make a better case to get Congress to support funding for an
invasive species line item. Over 70 percent of the respondents to
another question said that they knew of instances where federal
agencies do not have the resources to carry out actions in the national
management plan. While several respondents gave details on specific
examples of where they believe federal agencies have underfunded
invasive species programs, four others said that none of the agencies
have the resources to implement the management plan in its entirety.
In addition, 19 of the 21 respondents to one question said that the
council had inadequate staff resources to serve the needs of the
council. (The council has had a staff of five to seven people in the
last 2 years.) One respondent said that the “level of funding now is
token only and serves to support the most minimal staffing one can
imagine for a national effort of this scale. It’s embarrassing.” Many
of the respondents said that the council’s staff are working hard and
doing the best that they can. However, respondents also commented that
the staff is overwhelmed, faced with substantial obstacles, and is not
sufficient to support both the council and advisory committee. Several
respondents emphasized that the council staff should be larger to more
effectively push for implementation of the management plan.
Transition to New Administration:
Finally, the Executive Director of the council staff told us that, in
her opinion, progress on the management plan was slowed by the
transition to a new administration. High-level political appointments
are often vacant for months during the transition from one
administration to another. A senior official from the Department of the
Interior pointed out in July 2002 that many key managers relevant to
the crosscutting budget proposal had been in office only a few months
because of the time required to nominate and approve
political appointees.
The Current Regulations Concerning Ballast Water Management Are Not
Keeping Invasive Species Out of the Great Lakes:
According to experts and agency officials we consulted, current efforts
by the United States and Canada are not adequate to prevent the
introduction of nonnative aquatic organisms into the Great Lakes via
ballast water of ships, and they need to be improved. Compliance with
regulations is high but nonnative aquatic organisms are still entering
and establishing themselves in the Great Lakes ecosystem. U.S. and
Canadian agency officials believe that they should do more to protect
the Great Lakes from ballast water discharges. However, several time-
intensive steps must be taken before the world’s commercial fleet is
equipped with effective treatment technologies. In the meantime, the
continued introduction of nonnative aquatic organisms could have a
major economic and ecological impact on the Great Lakes.
Compliance with U.S. Regulations Is High, but Nonnative Aquatic
Organisms Are Still Entering the Great Lakes:
Since 1993, U.S. regulations have governed how vessels entering the
Great Lakes from outside the Exclusive Economic Zone, a zone extending
200 nautical miles from the shore, must manage their ballast
water.[Footnote 43] To be allowed to discharge ballast water into the
Great Lakes, ships must exchange their ballast water before entering
the zone and in water deeper than 2,000 meters.[Footnote 44] Exchanging
ballast water before arriving in the Great Lakes is intended to serve
two purposes: to flush aquatic organisms taken on in foreign ports from
the ballast tanks and to kill with salt water any remaining organisms
that happen to require fresh or brackish water. If a ship bound for the
Great Lakes has not exchanged its ballast water in the open ocean it
may hold the ballast in its tanks for the duration of the voyage
through the lakes. Under some circumstances--such as bad weather making
an open-ocean exchange unsafe--the Coast Guard may approve a ship
master’s request to do the exchange in an alternative exchange zone in
the Gulf of St. Lawrence.
The U.S. Coast Guard, the Saint Lawrence Seaway Development
Corporation, and the Canadian St. Lawrence Seaway Management
Corporation inspect ships as they enter and travel through the St.
Lawrence Seaway. The Coast Guard also inspects ships at U.S. ports
throughout the Great Lakes. Data from the Coast Guard show that
the percentage of ships entering the Great Lakes after exchanging their
ballast water has steadily increased since the regulations took effect
in 1993 and averaged over 93 percent from 1998 through 2001. (See
fig. 7.) Representatives of the Coast Guard and the seaway corporations
told us that the high exchange rate indicates that the current
regulations for the Great Lakes are being effectively
enforced.[Footnote 45]
Experts have concluded, however, that numerous nonnative aquatic
organisms have
entered the Great Lakes via ballast water and established populations
since the
regulations were promulgated. (See fig. 8.) Two such species are the
fish-hook
water flea (Cercopagis pengoi), discovered in 1998, and an amphipod (a
small crustacean) known as Echigogammarus ischnus, discovered
in 1995.[Footnote 46]
Figure 7: Rates of Compliance with Ballast Water Exchange Requirement
for Ships Entering the Great Lakes, 1992-2001:
[See PDF for image]
[End of figure]
Figure 8: Discovery of Nonnative Aquatic Species Introduced into the
Great Lakes and Major Legislation and Regulatory Decisions, 1985-2002:
[See PDF for image]
[End of figure]
Experts have cited several reasons for the continued introductions of
nonnative aquatic organisms into the Great Lakes despite the ballast
water regulations. First, the Coast Guard has not applied the ballast
water exchange regulations to ships with little or no pumpable ballast
water in their tanks; approximately 70 percent of ships entering the
Great Lakes during 1999 through 2001 were in this category. These
ships, however, may still have thousands of gallons of residual ballast
and sediment in their tanks. This could harbor potentially invasive
organisms from previous ports of call and could be discharged to the
Great Lakes during subsequent ballast discharges.
Second, there are also concerns that exchanging a particular percentage
of ballast water does not remove an equivalent percentage of organisms
from the tank. The Environmental Protection Agency and the Aquatic
Nuisance Species Task Force reported that ballast water exchange with
open-ocean water flushed 25 to 90 percent and 39 to 99.9 percent,
respectively, of the organisms studied. Researchers explain this range
by pointing out that organisms in sediment at the bottom of the tanks
may not be flushed out by an exchange.
Third, there is some uncertainty regarding what percentage of the water
in the tanks is actually flushed out during a typical ballast water
exchange. When determining whether tanks have been flushed and refilled
in the open ocean, the Coast Guard tests the new ballast water to see
if it has a salt concentration of at least 30 parts per
thousand.[Footnote 47] However, given uncertainties about the salinity
of a ship’s original ballast water and evaporative losses that occur
during transit, it is not clear from a basic salinity test
what percentage of the original ballast water--and the potentially
invasive aquatic organisms it may contain--has been removed.
Fourth, there is growing concern that freshwater organisms may be able
to survive the saline environment created by mid-ocean exchange.
Certain organisms have a stage in their life cycle during which they
are “resting eggs” or “cysts” and may be tolerant of salt water. Once
discharged into the Great Lakes freshwater system, these organisms can
regain viability. There are also examples of species--including
alewives and the sea lamprey--that normally spend part of their lives
in salt water and part in freshwater, but have been able to thrive
despite being “locked” into the freshwater of the Great Lakes.
In an effort to reduce the further introduction of nonnative species,
the Saint Lawrence Seaway Development Corporation and its Canadian
counterpart, the St. Lawrence Seaway Management Corporation, amended
their joint regulations in February 2002 to require all commercial
ships entering the Seaway system to comply with Great Lakes shipping
industry codes for ballast water management.[Footnote 48] These codes
contain “best management practices” that are intended to reduce the
number of organisms in ballast tanks. Such practices include not taking
on ballast at night--when marine organisms are more likely to be near
the surface--and regularly cleaning tanks.
Regulatory Decisions, Technological Developments, and Ship
Modifications Needed to Significantly Reduce Ballast Water Invasions
Will Take Many Years:
According to experts we consulted, it will take many years to solve the
problem of nonnative aquatic organisms arriving in ballast water. The
Coast Guard is now working to develop new regulations that would
include a performance standard for ballast water--that is, a
measurement of how “clean” ballast water should be before discharge
within U.S. waters. In May 2001, the Coast Guard requested comments on
how to establish a ballast water treatment standard and offered for
consideration four conceptual approaches. The agency received numerous
comments showing a wide range of opinion. As a result, it issued an
advanced notice of proposed rulemaking and another request for comments
in March 2002 on the development of a ballast water treatment goal and
an interim ballast water treatment standard. The Coast Guard is
expecting to have a final rule ready for interdepartmental review by
the fall of 2004 that will contain ballast water treatment goals and a
standard that would apply not only to ships entering the Great Lakes
but also to all ships entering U.S. ports from outside the Exclusive
Economic Zone.
Once the Coast Guard sets a new performance standard for how clean
ballast water should be, firms and other entities will have a goal to
use as the basis for developing and measuring treatment technologies.
Government, industry, academia, and other nongovernment interests are
investigating several technologies, including filtration,
hydrocyclonic separation, and chemical and physical biocides such as
ozone, chlorination, ultraviolet radiation, heat treatment, and vacuum.
Each technology has its strengths and weaknesses. One major hurdle
facing any technological solution is how to treat large volumes of
water being pumped at very high flow rates. Container vessels and
cruise ships, which carry a smaller volume of ballast water, may
require different technologies than larger container vessels. As a
result, it is likely that no single technology will address the problem
adequately. To facilitate technology development, the Coast Guard and
the Department of Transportation’s Maritime Administration are
developing programs to provide incentives for ship owners to actively
participate in projects designed to test treatment technologies.
To help with technology development, the National Invasive Species Act
created a ballast water demonstration program that funds select
proposals to develop and demonstrate new ballast water technologies.
Under this program, the National Oceanic and Atmospheric Administration
and the U.S. Fish and Wildlife Service have funded 20 ballast water
technology demonstration projects at a total cost of $3.5 million since
1998. Other programs also support research, such as the National Sea
Grant College Program, which has funded nine projects totaling
$1.5 million. In addition, the National Oceanic and Atmospheric
Administration, through the National Sea Grant College Program, and the
U.S. Fish and Wildlife Service announced on June 6, 2002, that they
expect to make $2.1 million available in fiscal year 2002 to support
projects to improve ballast water treatment and management. In
conjunction with this program, the Department of Transportation’s
Maritime Administration expects to make available several ships of its
Ready Reserve Force Fleet to act as test platforms for ballast water
technology demonstration projects. In fiscal years 2001 and 2002,
Congress appropriated $550,000 to the Coast Guard for research and
development related to ballast water management. In addition, EPA and
the Coast Guard expect to contribute $210,000 to fund a 3-year study on
the transfer of aquatic organisms in ballast water. Nonfederal
researchers in industry and academia are also studying the content of
ballast water and prospective treatment technologies. For example, a
Canadian shipping company funded the installation of a treatment system
on one of its ocean-going ships and allowed the Michigan Department of
Environmental Quality to perform testing on the system.
Once effective technologies are developed, another hurdle will be
installing the technologies on the world fleet.[Footnote 49] New ships
can be designed to incorporate a treatment system. Existing ships, on
the other hand, were not designed to carry ballast water technologies
and may have to go through an expensive retrofitting process. With each
passing year without an effective technology, every new ship put into
service is one more that may need to be retrofitted in the future.
Public and private interests in the Great Lakes have expressed
dissatisfaction with the progress in developing a solution to the
problem of nonnative aquatic organism transfers through ballast water.
An industry representative told us that she and other stakeholders were
frustrated with the Coast Guard’s decision to make a second request for
public comment on a treatment standard; she said they were anticipating
that the agency would publish a proposal rather than another request
for information. More broadly, in a July 6, 2001, letter to the
U.S. Secretary of State and the Canadian Minster of Foreign Affairs,
the International Joint Commission and the Great Lakes Fishery
Commission stated their belief that the two governments were not
adequately protecting the Great Lakes from further introductions of
aquatic invasive species.[Footnote 50] They also noted that there is a
growing sense of frustration within all levels of government, the
public, academia, industry, and environmental groups throughout the
Great Lakes basin and a consensus that the ballast water issue must be
addressed now. The two commissions suggested that the re-authorization
of the National Invasive Species Act is a clear opportunity to provide
funding towards implementing research aimed at developing binational
ballast water standards.[Footnote 51] The International Joint
Commission
recommended in its 2002 11th Biennial Report that the U.S. and Canadian
governments fund research recommended by expert regional, national,
binational
panels, task forces, and committees.[Footnote 52]
In an effort to prevent the introduction of nonnative aquatic organisms
into their waters, several Great Lake states have considered adopting
ballast water legislation that would be more stringent than current
federal regulations. For example, the legislatures in Illinois,
Minnesota, and New York are currently considering ballast water
legislation that would, among other things, require ships to
“sterilize” their ballast water--a standard that would exceed even
those for drinking water. The Michigan legislature also debated a
proposal that would have required ships to sterilize ballast water
before discharge. The stringency of that proposed legislation was a
result of one Michigan legislator’s frustration with the federal
government’s slow progress in implementing an effective national plan
to protect the Great Lakes from invasions through ballast water. The
bill that passed into law in Michigan, however, has requirements
similar to those in the federal program.[Footnote 53]
Citing inadequacies in the United States’ regulatory program, an
environmental organization petitioned EPA in 1999 on behalf of
15 nongovernmental, state, and tribal organizations to address ballast
water discharges under the Clean Water Act. The petition asked the
agency to eliminate the exemption that currently excludes ballast water
discharges from regulation under its National Pollutant Discharge
Elimination System program.[Footnote 54] Eighteen members of Congress
followed the petition with a letter also requesting that the agency
examine whether the Clean Water Act could be used to provide effective
regulation of nonnative aquatic organisms in ballast water. In its
September 10, 2001, draft response to the petition and the
congressional letter, the agency concluded that the exemption should
not be lifted because regulation of ballast water discharges under the
Clean Water Act would be more problematic than the process already in
place under the National Invasive Species Act. The agency asserted that
issuing uniform discharge requirements would require significant
federal and state agency resources and would not necessarily provide
protection greater than the National Invasive Species Act. The agency
also stated that the using the Clean Water Act would likely subject
ship operators to multiple and potentially different state and federal
regulatory regimes.
On the international level, the United States is also an active member
of the International Maritime Organization (IMO), a specialized United
Nations agency that is also addressing ballast water
management.[Footnote 55] In 1997, the organization adopted “Guidelines
for the Control and Management of Ships’ Ballast Water to Minimize the
Transfer of Harmful Aquatic Organisms and Pathogens.” The IMO requests
that all maritime nations adopt and use these voluntary guidelines that
call for, among other things, open-ocean ballast water exchange. Member
nations are also working toward an international convention to address
ballast water management. According to a State Department official who
is a member of the U.S. delegation to the IMO, the organization is
developing a new convention for possible adoption in the fall of 2003.
The State Department official told us that the convention would
probably include ballast water exchange as an interim method and would
likely include provisions for modifying the performance standard over
time to correspond with and spur improvements in technology. Even if a
convention were available for signature in the fall of 2003, it would
take some years for it to enter into force and for effective treatment
technologies to be installed on the world fleet. Recognizing the time
needed to develop and install new technologies, the Coast Guard has
suggested to the Marine Environment Protection Committee that the date
by which ships must meet a new performance standard be 10 years after
the organization adopts a convention (in this case, 2013).
The Continued Introduction of Nonnative Aquatic Organisms Via Ballast
Water Could Have Major Economic and Ecological Effects on the
Great Lakes:
Although no estimates have been made, using the past as a guide,
the continued introduction of nonnative aquatic organisms into the
Great Lakes could have significant economic and ecological impacts on
the Great Lakes basin.[Footnote 56] In a May 2001 report, the
International Joint Commission noted that the past and ongoing economic
impacts of invasive species introductions to the Great Lakes region
represent hundreds of millions of dollars annually.[Footnote 57] As a
result, experts dread the introduction of the “next zebra mussel.” The
zebra mussel was introduced to the Great Lakes in 1988 and is
continuing to wreak havoc on the ecosystem and surrounding economies.
Zebra mussel control measures alone are estimated to have cost
municipalities and industries $69 million from 1989 through 1995. (See
fig. 9 for more on the zebra mussel.):
Figure 9: Profile of the Zebra Mussel:
[See PDF for image]
[End of figure]
Such fears appear to be well founded because scientists predict that
additional invasions will occur if effective safeguards are not placed
on the discharge of ballast water from ocean-going ships. We have
discussed two species and listed others that have been introduced since
ballast water regulations were implemented. (See fig. 10.) In addition,
scientists have identified 17 species from the Ponto-Caspian region
(Caspian, Black, and Azov Seas) of Eastern Europe alone that have a
high invasion potential, are likely to survive an incomplete ballast-
water exchange, and are considered probable future immigrants to the
Great Lakes.
The continued introduction of nonnative aquatic organisms could further
damage a U.S. and Canadian Great Lakes sport and commercial fishing
industry that is valued at almost $4.5 billion annually and supports
approximately 81,000 jobs. Aggressive fish that have invaded the lakes
in the past (such as the sea lamprey, the Eurasian ruffe, and the round
goby) have harmed native fish by directly preying either on them or on
their food supply. Two of the potential species from the Ponto-Caspian
region, the amphipods Corophium curvispinum and Corophium sowinskyi,
could significantly alter biological communities along shorelines and
food chains in North American river systems. Invasive species can also
carry parasites and pathogens that could affect existing fish
populations. For instance, fish pathologists fear that continued
introductions of species such as the Eurasian ruffe may facilitate the
introduction of new and potentially harmful parasites and pathogens,
such as viral hemorrhagic septicemia, a serious disease of rainbow
trout in Europe that could affect North American fish populations.
Ballast water is also known to carry human pathogens, although the
risks they pose to human health has not been determined. One study
performed during the 1997 and 1998 shipping seasons sampled ballast
water in ships passing through the St. Lawrence Seaway en route to
ports in the Great Lakes.[Footnote 58] Human pathogens, such as fecal
coliform, fecal streptococci, Clostridium perfringens, Escherichia
coli, and Vibrio cholerae, as well as multiple species of
Cryptosporidium, Salmonella, and Giardia, were detected in the samples.
According to the Coast Guard, these organisms are also found in bodies
of water that are influenced by human development.
There Is a Growing Interest in Coordination between the United States
and Canada, but a Comprehensive Approach Has Yet to Be Developed:
The United States and Canada participate in a variety of bilateral and
multilateral efforts to share information, conduct research, and
coordinate efforts to reduce the threat of invasive species. The two
countries’ long history of coordination has focused on particular
segments of the issue such as shared boundary waters and agricultural
research, and stakeholders have called for a more comprehensive
strategy for joint prevention and management efforts. The National
Invasive Species Council recognized the need for the United States to
work with Canada (and Mexico) in a more comprehensive manner and has
taken initial steps to develop a North American strategy as called for
by the national management plan. It is too early to tell, however, what
form a North American strategy will take or how existing organizations
will be integrated.
Coordination Between the Two Governments Has Focused on Specific Issues
or Geographic Regions:
Historically, coordination between the United States and Canada has
focused on specific pathways, species, or geographic areas rather than
on a comprehensive coordinated approach. Primary examples of this
coordination concern shared boundary waters and agriculture.
Shared Boundary Waters:
One mechanism for coordination is the International Joint Commission,
which was established by the Boundary Waters Treaty of 1909. The treaty
established the commission to advise the U.S. and Canadian governments
concerning issues along the boundary and approve certain projects in
boundary and transboundary waters that affect water levels and flows
across the boundary. The commission has focused much of its attention
on the Great Lakes. The purpose of the 1978 Great Lakes Water Quality
Agreement between the United States and Canada is to “restore and
maintain the chemical, physical, and biological integrity of the waters
of the Great Lakes Basin Ecosystem.” The International Joint
Commission’s role with respect to the agreement includes evaluating and
assessing the two countries’ programs and providing a report at least
every 2 years that presents its findings, advice, and recommendations.
Recent reports have contained recommendations to the governments on how
to
reduce the flow of invasive species through ballast water.[Footnote 59]
Protection of the Great Lakes fisheries against the nonnative sea
lamprey was a motivating factor behind the creation of the Great Lakes
Fishery Commission in 1955 in the Convention on Great Lakes Fisheries
between the U.S. and Canada. The fishery commission, which is jointly
funded by the two countries, has been largely successful in
controlling, although not eradicating, the sea lamprey. Another primary
objective of the fishery commission is to formulate a research program
or programs to determine the need for measures to make possible the
maximum sustained productivity of fish of common concern. One of the
commission’s goals is to ensure that no nonnative fishes will be
unintentionally introduced into the Great Lakes. The commission has
stated that it will intensify its work with partners to address those
vectors for invasive species, such as ship ballast water, that pose the
greatest threat to the lakes.
Another mechanism that has promoted coordination between the United
States and Canada is the establishment of regional panels to address
aquatic invasive species. The Nonindigenous Aquatic Nuisance Prevention
and Control Act of 1990 authorized the establishment of the Great Lakes
Panel on Aquatic Nuisance Species, which comprises U.S. and Canadian
public-and private-sector representatives.[Footnote 60] Its activities
include identifying Great Lakes priorities for aquatic nuisance
species, coordinating information and education efforts, making
recommendations to the federal government, and advising the public
about control efforts. Two other U.S. panels recently established under
the National Invasive Species Act of 1996 in the West and the Northeast
also include Canadian members.
As noted earlier, the United States and Canada are also working
together on managing ballast water coming into the Great Lakes through
the St. Lawrence Seaway. Cooperative efforts by the two countries were
most recently demonstrated by the joint decision of the United States’
Saint Lawrence Seaway Development Corporation and Canada’s
St. Lawrence Seaway Management Corporation to require all ships
entering the seaway to follow established best management practices.
Agricultural Research and Pest Control:
There has also been a long history of coordination between the U.S. and
Canada in the area of agricultural research and pest control. As we
reported in July 2002, for over 30 years the two countries and Mexico
have held regular meetings on animal health issues to make North
America’s import requirements consistent and, more recently, to
coordinate preventive actions and emergency response activities in the
event of an outbreak of the nonnative foot-and-mouth disease.[Footnote
61] In 2000, the three countries held joint exercises to test their
foot-and-mouth disease communication and response plans and to assess
their response systems. As a result of this exercise, the three
governments signed a memorandum of understanding to formally establish
the North American Animal Health Committee. According to USDA, the
United States and Canada have also worked very closely in the past
several years on jointly assessing the threat from two other foreign
animal diseases--bovine spongiform encephalopathy (also known as “mad
cow disease”) and chronic wasting disease. Another emerging animal and
public health issue that the United States and Canada have worked
together on is the West Nile virus, which is transported by migratory
birds and by insects such as mosquitoes. (See fig. 10 for more details
on the virus.):
Figure 10: Profile of West Nile Virus:
[See PDF for image]
[End of figure]
To further strengthen communication and collaboration on invasive
species and trade-related matters, USDA’s Animal and Plant Health
Inspection Service established an office in Ottawa, Canada, in 2000.
The office oversees a preclearance program throughout Canada that
conducts inspections, treatments and/or other mitigation measures in
Canada to identify and/or mitigate the risk of exotic pest
introductions via agricultural commodities before the commodities are
cleared through the U.S. Customs Service.
Another vehicle for coordination in the agriculture sector is the
North American Plant Protection Organization, created as a regional
plant protection organization under the International Plant Protection
Convention of 1951. The convention called for the governments to
establish regional plant protection organizations responsible for
coordinating activities under the convention, such as the development
and promotion of the use of international phytosanitary
certificates.[Footnote 62] For example, through the plant protection
organization, the United States, Canada, and Mexico worked together to
develop a standard for treating solid wood packing materials. According
to USDA, the United States and Canada are also working together to
develop an international standard for evaluating the environmental
impact of invasive species. This standard, which the USDA expects to be
adopted by the International Plant Protection Convention in 2003, would
provide a common framework for assessing the invasive potential of
pests and thereby ensure a more rigorous but common approach to dealing
with them.
Stakeholders Have Called for Increased Coordination between the United
States and Canada:
While there are numerous examples of coordination between the United
States and Canada on invasive species control, some stakeholders in
this issue believe that not enough is being done. For example, in June
1999, the Great Lakes Panel on Aquatic Nuisance Species wrote that
there was a lack of inter-jurisdictional consistency in laws,
regulations, and policies directed at aquatic nuisance species
prevention and control efforts, and that improvements were needed to
ensure a more efficient and effective regional prevention and
control program.
As noted previously, the International Joint Commission stated its
belief that the two governments were not adequately protecting the
Great Lakes from further introduction of aquatic invasive species and
it made several recommendations regarding a binational approach to
better management. In addition, according to EPA, there are numerous
locations where there is a need for continuing regional cooperation to
address aquatic invasive species in binational waterways, including the
St. Croix River of New Brunswick and Maine; Lake Champlain of Quebec,
Vermont, and New York; the Red River of North Dakota, Minnesota, and
Manitoba; the Souris River of Saskatchewan, Manitoba, and North Dakota;
and the Georgia Basin-Puget Sound of British Columbia and Washington.
For example, in the Red River watershed of North Dakota, a proposed
water diversion could introduce nonnative species into new locations.
An official from EPA’s Office of International Affairs told us that, in
his opinion, having an overarching policy with respect to aquatic
invasive species along the border would help better address these
situations more quickly or avoid them completely.
The National Invasive Species Council’s Assistant Director for
International Policy, Science, and Cooperation told us that she
believes that the United States could expand two existing interagency
organizations--the Federal Interagency Committee for the Management of
Noxious and Exotic Weeds and the Aquatic Nuisance Species Task Force--
to include Canadian representation, or that Canada should be encouraged
to develop similar organizations.[Footnote 63] She said this would make
it much easier to establish dialogue between officials with similar
responsibilities. The council’s Assistant Director also said she
thought that the National Oceanic and Atmospheric Administration’s Sea
Grant Program could be more effectively used to support educational
programs developed and implemented in the United States and Canada. She
noted that because tourists frequently cross the border to and from
Canada it is important to address this pathway with a common education
strategy. In this same vein, while we reported in August 2002 that the
United States, Canada, and Mexico have worked to coordinate animal
health measures, we also noted that there are differences in the
countries’ policies and practices with regard to foot-and-mouth disease
that could contribute to the risk that travelers may bring foreign
animal disease across our mutual borders.
The National Invasive Species Council Has Taken Initial Steps Toward
Developing a North American Strategy, but its Form Is Not Yet Known:
The National Invasive Species Council recognized the need for the
United States to work with Canada (and Mexico) in a more comprehensive
manner. The management plan called for the council to outline an
approach to a North American invasive species strategy by
December 2001. The strategy was to be built upon existing tripartite
agreements and regional organizations. The plan also called for the
council to initiate discussions with Canada and Mexico for further
development and adoption of the strategy. The council has taken initial
steps but has not completed this planned action.
The council established the North America Strategy task team in
January 2002. It comprises federal and nonfederal stakeholders, and is
cochaired by the Department of State, the Environmental Protection
Agency, and the Fish and Wildlife Service. In March 2002, the
Department of State sent a cable to United States embassy staff in
Canada and Mexico requesting that they notify officials in those two
countries of the federal government’s desire to develop a North
American strategy. According to one U.S. official involved in this
project, Canadian representatives have responded positively to
the idea.
In the time since it sent the memorandum, however, the team has done
little to develop the strategy. The council staff and the advisory
committee placed the team into a holding pattern in May 2002 when they
decided that all of the implementation teams needed to be reviewed by
the advisory committee. According to one of the cochairs of the team,
among other things that the team will need to do is identify the
objectives of the U.S. participation in the various North American
organizations and determine what actions are being taken.
Two other multilateral organizations provide opportunities for a more
comprehensive approach to an invasive species strategy across
North American borders but do not have significant resources dedicated
to the issue. The North American Commission on Environmental
Cooperation, which is governed by a council composed of the
Administrator of the United States Environmental Protection Agency,
the Minister of the Environment in Canada, and the Secretary of the
Environment and Natural Resources in Mexico, provides an opportunity
for the United States and Canada to research and develop strategic
plans for common ecosystems such as northern forests, grasslands, and
aquatic ecosystems.[Footnote 64] One objective in its 2001 draft
Strategy
for the Conservation of Biodiversity in North America, is to promote
the
development of concerted efforts to combat invasive species in North
America. In March 2001, participants at a workshop sponsored by the
commission recommended five priority areas for cooperation in North
America on invasive species. Because of limited resources, however, the
commission has decided to proceed with just one of those areas--
identifying invasive species and invasion pathways that are a concern
of two or more countries (within North America)--and determine
priorities for bi-or tri-lateral cooperation.
The Trilateral Committee for Wildlife and Ecosystem Conservation and
Management is composed of the wildlife agencies from the United States,
Canada, and Mexico, and also has the ability to look at approaches for
managing invasive species more broadly.[Footnote 65] The committee has
not analyzed invasive species in depth, although the issue was on its
meeting agenda in April 2002 in order to set it as a topic for
discussion at a later meeting. According to a State Department official
who attended the meeting, the committee decided to add invasive species
to the portfolio of the “working table” on biodiversity information.
Conclusions:
While the available data are often inadequate to thoroughly describe
the costs and risks associated with invasive species, it is apparent
that their impacts on our environment and, thus, our economy are
significant. At the same time, because of limitations in both the
quantity and quality of economic impact analysis, it may not be readily
apparent to decision makers in the federal government how they should
most effectively allocate limited resources to prevent and manage
invasive species. It is encouraging that the National Invasive Species
Council and OMB are working on a crosscut budget that the federal
government can use to plan resource allocations to and among
departments. Such decisions would be better informed by information and
data on the risk that nonnative species will enter the country, become
established, spread, and cause harm. The ballast water management
situation is a prime example. The federal government faces decisions
about dedicating resources to fund ballast water technology research or
standard setting, and ultimately about imposing more protective
regulations. Decision makers could weigh the costs of those activities
against the potential costs of the next zebra mussel or sea lamprey to
arrive in U.S. waters, if such data were readily available.
Moving ahead with a comprehensive management plan to combat invasive
species is clearly in the national interest. It also poses a daunting
challenge. Success in this effort will depend in no small part on
crafting a plan that calls for clearly defined, measurable outcomes and
has a mechanism in place to hold departments accountable for carrying
it out. The National Invasive Species Council now has the opportunity
to improve upon its management plan in a revision due in 2003.
Successful implementation of the plan depends in part on the members of
the council making it a priority within their own departments and
agencies and, recognizing the enormity of the task ahead, developing
estimates of the resources needed. Statements from various stakeholders
suggest it is possible that federal agencies could better coordinate
their efforts to implement the management plan if the Congress
established the council in legislation. The management plan states that
the council will conduct an analysis of legislative authorities
relevant to invasive species. We believe that the evaluation should
also examine the question of whether the lack of legislative authority
establishing the council is hampering the council in its efforts to
implement the national management plan.
Recommendations for Executive Action:
To better manage the threats posed by invasive species in the United
States, we recommend that the cochairs of the National Invasive Species
Council--the Secretaries of Agriculture, Commerce, and the Interior--
direct council members to:
* Include within the revision to the National Invasive Species
Management Plan a goal of incorporating information on the economic
impacts and relative risks of different invasive species or pathways
when formulating a crosscuting invasive species management budget for
the federal government. Such a goal may require a commitment from the
council to ensure that adequate resources are dedicated within the
federal government to expand the capacity for conducting appropriate
economic analysis.
* Ensure that the updated version of the national management plan, due
in January 2003, contains performance-oriented goals and objectives and
specific measures of success.
* Give a high priority to completing planned action #1, which calls for
establishing a transparent oversight mechanism for use by federal
agencies in complying with Executive Order 13112 and reporting on
implementation of the management plan.
* Include in its planned evaluation of current legal authorities an
examination of whether the lack of legislative authority establishing
the National Invasive Species Council and specifically directing its
members to implement the national management plan hampers the council’s
efforts to implement the plan.
To better ensure the implementation of the national management plan,
we recommend that the members of the National Invasive Species Council
who are responsible for taking actions called for in the plan recognize
their responsibilities in either their departmental-or agency-level
annual performance plans. The annual performance plans and performance
reports should describe what steps the departments or their agencies
will take or have taken to implement the actions that are specifically
called for in the national management plan. For the existing (2001
version) of the national management plan, the member departments to
which this applies include the Departments of Agriculture, Commerce,
Interior, Defense, State, and Transportation, and the Environmental
Protection Agency.
Agency Comments and Our Evaluation:
We provided copies of our draft report to the Departments of
Agriculture, Commerce, Defense, Treasury, State, Transportation, and
the Interior; the Environmental Protection Agency; the U.S. Trade
Representative; and the National Invasive Species Council. We received
written comments from the Department of the Interior, the Department of
State, the Environmental Protection Agency, and the National Invasive
Species Council. We received oral comments from the Departments of
Transportation, Agriculture, and the Treasury. The written comments
from the Department of the Interior, the Department of Agriculture, the
National Invasive Species Council, and EPA are in appendixes II
through V.
The Department of the Interior concurred with the recommendations in
the report and said that it would work with the other cochairs of the
National Invasive Species Council to implement the recommendations in a
timely manner consistent with current budget and authority. While
agreeing with the recommendations, the department expressed the view
that our draft report did not adequately acknowledge the extensive
invasive species activities that federal agencies are doing outside of
what is called for by the national management plan. We agree that
federal agencies are engaged in other invasive species management
activities and have described many of them in prior reports. A
principle objective of this review, however, was to assess the
implementation of the national management plan, and not all federal
activities. The department also commented that it believes that the
Fish and Wildlife Service, the National Oceanic and Atmospheric
Administration, and the Maritime Administration are demonstrating
substantial progress in developing technologies to treat ballast water.
We agree that progress is being made, but continue to believe that much
important work remains to be done. To illustrate this, we reported the
Coast Guard’s estimate that it may be at least 10 years before ships
must meet a new performance standard for ballast water treatment, a
step critical to real progress. The department suggested several other
minor changes that we have incorporated where appropriate.
The Department of State commented that it did not fully concur with our
finding that the slow progress on the national management plan is due
to lack of priority given to the plan by the Council and departments.
The department claimed that it places a high priority on accomplishing
the goals of the management plan, and it itemized numerous activities
in support of that statement. We do not disagree with the department’s
claims. However, we did not evaluate the efforts or progress of one
department versus another; instead, we evaluated implementation of the
management plan overall. The letter from the Department of State also
included comments from the International Joint Commission. The
commission suggested that we include a recommendation that the federal
government work with Canada to develop an effective approach to
immediately improve the management of all ballast waters coming into
the Great Lakes. Our report describes the current and expected
situation with respect to ballast water in the Great Lakes. We believe
that the decision to take more immediate action to solve the problem is
a policy decision best left to the Congress or the administration. The
commission also suggested that we ask the Congress to consider
completing reauthorization of the National Invasive Species Act. While
we recognize the importance of the commission’s suggestion, we did not
evaluate the current proposal to reauthorize the act. The department
and the commission also offered minor corrections, which we have made.
The National Invasive Species Council concurred with our
recommendations but made several clarifying comments. In particular,
it noted that the management plan’s deadlines were optimistic and
suggested that we should have evaluated whether the deadlines were
realistic or attainable. We believe that an assessment of its deadlines
is an appropriate task for the council when it revises the management
plan. In addition, the council commented that the report undervalued
the progress being made toward coordination and cooperation among
federal agencies and gave examples of such activity. We acknowledge
that coordination between departments has increased as a result of the
creation of the council and the management plan, and we have added
language to support this point. Nevertheless, the report provides
support for the position that improvement can still be made in this
area. Finally, the council made other minor comments that we have
incorporated where appropriate.
The Environmental Protection Agency commented that our recommendations
were reasonable and believes that their implementation would enhance
the federal government’s response to dealing with the problem of
invasive species. The agency also noted that the report is well written
and helpful in assessing the progress made in coping with invasive
species. The agency also made several clarifying comments that we have
incorporated where appropriate. The agency questioned whether we should
have based our conclusions about the pace of implementation of the
management plan solely on the results of our survey of the members of
the first term of the advisory committee, given the small size of the
population and their possible biases. We did not draw our conclusions
about the pace of implementation solely, or even primarily, from the
survey. Our statement that less than 20 percent of the plan has been
implemented is based on our analysis of information from the National
Invasive Species Council staff and the council’s member departments.
EPA also noted that the report’s section on ballast water focused on
the Great Lakes and pointed out that work is being done and needs to be
done in other parts of the country. We agree that ballast water is an
important issue in other parts of the country. However, our objective,
as part of our coordinated review with the Canadian Office of the
Auditor General, was to focus on the Great Lakes. Finally, EPA made a
number of technical clarifications that we have incorporated, where
appropriate, in the report.
The invasive species coordinator for the Department of Agriculture said
that our comments on the implementation of the national management plan
were fair and on target. This official also provided two minor
clarifying comments that we have incorporated.
The Department of Transportation’s Director for Performance Planning in
the Office of Budget and Program Performance provided oral comments on
the draft. He told us that the department disagreed with our draft
recommendation calling for the members of the National Invasive Species
Council to incorporate the national management plan into their annual
performance plans. He said that the department does not believe that it
is appropriate to include performance goals with respect to invasive
species in its performance plan because managing invasive species is
not one of its core missions. In addition, he told us that the agencies
within the department that have a more direct role with respect to
invasive species, such as the Coast Guard, Maritime Administration, and
Federal Highway Administration, are at liberty to include invasive
species management goals in their annual performance plans. In response
to this comment, we modified the wording of the recommendation to
specify that the national management plan should be addressed in the
most appropriate annual performance plan, whether at the departmental
level or the agency level. The department also commented that there are
many mechanisms other than ballast water by which invasive species are
introduced into the environment. We agree, and noted some of them in
the report. However, our objective specifically focused on the issue of
ballast water in the Great Lakes.
A representative with the Office of Planning in the Department of the
Treasury’s U.S. Customs Service told us that because the current
national management plan does not call for the Customs Service to
undertake significant activity on invasive species, it does not believe
that it is appropriate for it to address the management plan in its
annual performance plan as called for in our recommendation. We
acknowledge that the current plan does not have action items directed
to the Customs Service, and we modified our recommendation to clarify
its applicability to those member agencies that are specifically
responsible for action items in the existing (2001) national management
plan. If future versions of the plan specify action items for other
agencies, we would encourage them to follow the same practice with
regard to their department-or agency-level annual performance plans.
The Customs Service made no technical comments.
We are sending copies of this report to the other members of the
National Invasive Species Council: the Secretaries of State, Defense,
Transportation, Health and Human Services, and Treasury, and the
Administrators of the Environmental Protection Agency and the
U.S. Agency for International Development. We are also sending copies
of this report to the Chairmen and Ranking Minority Members of the
following congressional committees: the Senate Committee on
Agriculture, Nutrition, and Forestry; the Senate Committee on
Commerce, Science, and Transportation; the Senate Committee on
Environment and Public Works; the Senate Committee on Energy and
Natural Resources; the Senate Committee on Foreign Relations; the
Senate Committee on Appropriations; the House Committee on Agriculture;
the House Committee on Resources; the House Committee on Science; the
House Committee on Transportation and Infrastructure; the House
Committee on Energy and Commerce; the House Committee on International
Relations; and the House Committee on:
Appropriations. We will make copies available others upon request. This
report is also available on our Web site at www.gao.gov. If you have
any questions concerning this report, I can be reached at (202) 512-
6878. Major contributors to this report include Trish McClure, Ross
Campbell, Patrick Sigl, Don Cowan, Anne Stevens, and Amy E. Webbink.
David G. Wood
Director, Natural Resources
and Environment:
Signed By David G. Wood:
[End of section]
Appendixes:
Appendix I: Scope and Methodology:
To determine the usefulness to decision makers of economic impact
studies for invasive species in the United States, we reviewed
economics and other policy literature that analyzes invasive species’
effects on the U.S. economy and ecosystems. We also reviewed the
literature that describes and evaluates U.S. regulatory policies for
invasive species. We paid particular attention to the literature that
evaluates how well cost-benefit analyses of invasive species’ effects,
and of regulatory policies to control them, have been adjusted to
reflect uncertainties and risks associated with these assessments. To
further determine the usefulness of the existing studies, we selected
and interviewed experts, including some authors of studies, and
government officials involved in both authoring and using the economic
impact studies. We identified these experts through our literature
search.
To assess the National Invasive Species Management Plan, including the
extent to which the United States government has implemented it, we
first analyzed the content of the plan in relation to the requirements
spelled out in Executive Order 13112. In particular, we analyzed the
extent to which it contained “performance-oriented goals and objectives
and specific measures of success for federal agency efforts concerning
invasive species.” The plan contains 57 enumerated actions. However,
several of those actions have distinct subparts. In consultation with
council staff, we agreed that there are a total of 86 distinct actions
called for by the plan. To evaluate the extent to which the plan has
been implemented, we focused primarily on those actions that had a
start or completion date of September 2002 or earlier. There are 65
actions in that category. To determine whether actions had been
completed, were in progress, or had not been started, we relied on the
National Invasive Species Council’s summary of agency progress,
materials provided to us by agency officials, and interviews with
council staff and agency officials. For those actions that had been
started but not completed, we did not attempt to characterize the
extent to which they had been completed. In only a few instances did we
attempt to determine when incomplete actions would be complete.
To assist in our evaluation of the plan and our assessment of its
implementation, we surveyed the 32 people serving on the Invasive
Species Advisory Committee for a 2-year term beginning in December
1999. We had several reasons for surveying this group: (1) they
participated in developing the national management plan; (2) they
represented a wide range of interests relevant to the invasive species
issue; and (3) by virtue of their professions and their involvement
with the committee, they were likely to have information and opinions
on how the management plan was being implemented. The Secretary of the
Interior reappointed 15 of these 32 people for another term on the
advisory committee beginning in April 2002.
One of the members of the original advisory committee told us that he
had resigned from the committee partway through his term and did not
believe that he was informed enough about events surrounding the
council, the committee, or the management plan to respond to our
survey. Therefore, for the purposes of calculating a response rate, we
are using 31 as the size of our survey population. Twenty-one of the 31
members of the committee completed our survey, while 2 others completed
a small portion of the survey. Therefore, while the response rate was
74 percent, the completion rate was 68 percent. Thirteen of the 15
people reappointed to the committee responded to the survey.
The survey instrument contained questions that asked for either
numerical or open-ended answers. The survey, including a tally of the
numerical answers, is in appendix IV. Because we did not take a sample
of the committee members, the numerical answers are presented as a
straight percentage of the total number of respondents. There are no
error rates associated with the results. We did not reprint the open-
ended answers in the report because they are too numerous and lengthy.
To determine the experts’ views on the adequacy of U.S. and Canadian
efforts to control the introduction of invasive aquatic species into
the Great Lakes via the ballast water of ships, we selected and
interviewed experts from various stakeholder interests. We identified
experts through a literature search and by soliciting the names of
other expert contacts throughout our review. In the end, we contacted
experts from U.S. federal agencies, academic institutions, and the
shipping industry. We also met with staff from two binational agencies-
-the International Joint Commission and the Great Lakes Fishery
Commission--and with representatives of the Great Lakes Commission. In
addition, we attended a conference on aquatic nuisance species to
obtain opinions from a range of stakeholders on ballast water and
associated shipping vectors.
To describe the current management of ballast water in the Great Lakes,
we researched U.S. and Canadian legislation, regulations, and
guidelines. In order to determine the compliance rate and effectiveness
of the current regulatory regime for the Great Lakes, we obtained
compliance and other data from the Coast Guard Marine Safety Detachment
and the Saint Lawrence Seaway Development Corporation in Massena,
New York. The Saint Lawrence Seaway Development Corporation also showed
us the U.S. ballast water inspection procedures on a vessel docked in
Montreal, Canada, and bound for the Great Lakes. We also reviewed
studies on the introduction of nonnative aquatic organisms traced to
ballast water, paying particular attention to those that have invaded
after the ballast water regulations for vessels entering the
Great Lakes took effect in 1993. We interviewed both United States and
Canadian scientists on the significance of the continued invasions
since 1993.
For the international perspective on ballast water management, we
reviewed the history and development of the current International
Maritime Organization policies and guidelines. We also met with members
of the U.S. delegation to the organization to determine the status of
negotiations on a future international agreement related to ballast
water. These officials represent the United States on the Marine
Environmental Protection Committee and lead the correspondence group
that is tasked with developing a performance standard for the future
International Maritime Organization Convention on ballast water
management.
To describe coordination between the United States and Canada, we
interviewed officials from departments in the National Invasive Species
Council to determine if their departments were involved in any
significant efforts to coordinate with Canadian officials on invasive
species management. From these discussions, we learned that
coordination efforts on a binational (or in some cases trinational)
level have focused primarily on shared boundary waters and agriculture.
We obtained further information from the relevant departments on the
nature of those coordination efforts. To learn more about how
nonfederal organizations can play a role in coordinating the work of
the two countries, we interviewed and obtained documents from officials
representing the International Joint Commission, the Great Lakes
Fishery Commission, the Great Lakes Commission, and the North American
Commission on Environmental Cooperation. We also obtained documentation
that described relevant work being done by the International Plant
Protection Organization, the North American Plant Protection
Organization, the North American Animal Health Committee, and the
Trilateral Committee for Wildlife and Ecosystem Conservation and
Management. Finally, we relied on previous GAO work on foot-and-mouth
disease.
In choosing invasive species to profile, we judgmentally selected
species that (1) illustrate problems in a variety of environments
(aquatic, terrestrial, managed, and natural areas), (2) are drawn from
a wide variety of taxonomic groups (vertebrate, invertebrate, virus,
and plant), (3) include some that are well known by the public and
others that are not, and (4) provide a selection whose distribution
collectively covers a large portion of the United States. We collected
and reviewed data on the species from federal agencies, academic
institutions, and previous GAO reports. We obtained photographs of
species from the U.S. Geological Survey and USDA.
We conducted our review from November 2001 through September 2002 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: Survey of Charter Members of the Invasive Species Advisory
Committee:
[See PDF for image]
[End of figure]
[End of section]
Appendix III: Comments from the Department of the Interior:
United States Department of the Interior:
OFFICE OF THE SECRETARY Washington, D.C. 20240:
OCT 1 5 2002:
Mr. David G. Wood:
Director, Natural Resources and Environment United States General
Accounting Office 441 G Street, NW:
Washington, DC 20548:
Dear Mr. Wood:
Thank you for the opportunity to respond to the draft report entitled,
“Invasive Species: Clearer Focus and Greater Commitment Needed to
Effectively Manage the Problem” (GAO-03-01). The Department concurs
with the recommendations of this report and will work with the other
Co-Chairs of the National Invasive Species Council to implement the
recommendations in a timely manner consistent with current budget and
authority. Our efforts to develop a budget crosscut on Invasive Species
for FY 2004 should further support the report’s recommendations.
Our specific response to each of the draft report recommendations is
provided in the enclosure. If you have further questions, please
contact A. Gordon Brown, DOI Invasive Species Coordinator, at (202)
513-7245.
Sincerely,
P. Lynn Scarlett:
Assistant Secretary for Policy, Management and Budget:
Signed by P. Lynn Scarlett:
Enclosure:
Department of the Interior Comments on GAO Draft Report entitled,
“Invasive Species: Clearer Focus and Greater Commitment Needed to
Effectively Manage the Problem” (GAO-03-01):
General Comments:
The recommendations of the report are directed to the National Invasive
Species Council (Council) co-chairs. Since the Department of the
Interior is a co-chair of the Council, the Department will work
cooperatively with the other co-chairs, in the Departments of
Agriculture and Commerce, to address the report’s recommendations.
The Department supports development of a budget crosscut on invasive
species for FY 2004 and later requests by the Council departments. We
believe this will lead to development of a performance-based strategic
plan for most of the Executive Branch agencies.
Specific Comments:
Fish and Wildlife Service clarified an error of fact on Page 21 - “In
addition, the Federal Aquatic Nuisance Species Task Force has developed
a process to evaluate the risk of introducing non-native organisms into
a new environment and, if needed, determine the correct management
steps to mitigate that risk. The task force has used this process to
provide guidance to states for designing their own management plans for
aquatic nuisance species.”:
The second sentence of this statement is incorrect in that the risk
assessment process is separate from the State management planning
process. The second sentence should be modified to read: “The Task
Force has also developed guidelines to provide direction to assist
States in the development of their own management plans for aquatic
nuisance species.”:
Recommendation #1: that the co-chairs of the Invasive Species Council-
the Secretaries of Agriculture, Commerce, and the Interior-include
within the revision of the National Invasive Species Management Plan, a
goal of incorporating information on economic impacts and relative
risks of different invasive species or pathways when formulating a
budget crosscut.
The Department of the Interior, in consultation with the other co-
chairs, will work to expand the capacity for conducting appropriate
economic analysis on invasive species and their impacts.
Recommendation #2: that the co-chairs of the Invasive Species Council-
the Secretaries of Agriculture, Commerce, and the Interior-ensure that
the next edition of the national management plan contains performance-
oriented goals and objectives and specific measures of success.
The Department of the Interior is working to advance activity-based
costing as a model of performance budgeting and management for its own
programs. A pilot program of performance-oriented goals and objectives
with specific measures of success will be implemented in January 2004
for the National Invasive Species Council. This information will be
used to build a more:
complete budget crosscut proposal on invasive species for FY 2005,
including shared goals, strategies and performance measures.
Recommendation #3: that the co-chairs of the Invasive Species Council-
the Secretaries of Agriculture, Commerce, and the Interior-give a high
priority to completing planned action #1, a Federal oversight mechanism
for compliance with EO 13112 and management plan implementation.
The Department of the Interior will cooperate with the other co-chairs
to jointly provide leadership on this issue and solicit consensus views
on any proposal from the Invasive Species Advisory Committee.
Recommendation #4: that the co-chairs of the Invasive Species Council-
the Secretaries of Agriculture, Commerce, and the Interior-include in
its planned evaluation of current legal authorities an examination of
the importance of legislative authority to National Invasive Species
Council implementation of the national management plan.
The Department of the Interior will work with the other co-chairs to
assess legislative authority for a national invasive species management
plan.
Comments supplied by the bureaus:
Fish and Wildlife Service:
Page 33 - “One respondent thought that federal departments and agencies
were continuing to pursue their own mandates and programs with only a
cursory regard for the framework and coordination that the council
attempts to provide. “:
The National Invasive Species Management Plan (ISMP) is a critical
document helping to focus department and agency invasive species
activities; however, Federal agencies are also guided by other policies
and legislation that direct their activities. Many of these activities
are conducted by the agencies and are not reflected in the actions
outlined in the ISMP. The GAO report gives a critical review of the
Federal government’s efforts to implement the ISMP with minimal
acknowledgment of these extensive activities that balance invasive
species workloads to meet both existing responsibilities and new
activities outlined in the ISMP. In addition, we point out that the
Council has made great strides in coordinating agency activities and
increasing communication among agencies and departments about their
invasive species activities.
Page 34 - “In our view, the relationship of the advisory committee to
the implementation teams has slowed progress on the plan and could
continue to do so. While we understand why the council decided to form
the implementation teams under the auspices of the advisory committee -
to foster consensus among key stakeholders early in the implementation
process - we believe that this decision may slow Federal action.
Specifically, it may be difficult for teams of Federal and non-federal
stakeholders to put forth the concerted effort needed to implement the
management plan. “:
While we agree that progress might have been made more quickly without
input from the Advisory Committee, we support the Council’s decision to
proceed with a partnering process that incorporates input from the
stakeholder Advisory Committee.
Page 37 - “The current regulatory approach to ballast water management
is not keeping invasive species out of the Great Lakes “.
While we agree that ballast water continues to be a major pathway for
introductions of aquatic invasive species, we believe that the progress
being made on monitoring and compliance by the Coast Guard to develop
and implement regulations is timely and reflects the time-consuming
nature of the regulatory process. We also believe that the efforts by
the Fish and Wildlife Service, the National Oceanic and Atmospheric
Administration, and the Maritime Administration are demonstrating
substantial progress to develop technologies to treat ballast water to
remove invasive species.
Page 54 - “The National Invasive Species Council’s Assistant Director
for International Policy, Science, and Cooperation told us that she
believes that the United States could expand two existing interagency
organizations - the Federal Interagency Committee for the Management of
Noxious and Exotic Weeds and the Aquatic Nuisance Species Task Force -
to include Canadian representation. . . “:
The Aquatic Nuisance Species Task Force (ANS) has Canadian
representation in an “invited observer” status. In addition, the ANS
Task Force has actively recruited Canadian representation in the
efforts of its numerous committees. For example, three of the Regional
Panels of the Task Force (Northeast, Great Lakes, and Western) have
Canadian representatives serving on the committees.
National Park Service:
The draft report dwells on the need for more comprehensive data and
analysis of risks and of economic and ecological costs of invasive
species. We recognize that others may need this information, but we
would like to point out that lack of information is not a major
hindrance to our efforts to control invasive species.
We have a major Inventory and Monitoring Program in the National Park
Service and some of the funds allocated for weed management are used
for inventory and monitoring. We know where our weeds are and we know
why we are controlling them. We do not wait for more information to
implement an effective program. Our greatest need is for more funds for
operational work.
Further, quantification of the costs of invasive species will tend to
favor management of invasive species in situations where the costs can
be easily given monetary value. Costs to agriculture are easily
quantified in monetary terms whereas costs to natural areas are
difficult to quantify. Therefore, generation of this data will tend to
favor funding of control for invasive species that affect agriculture,
at the expense of natural areas control efforts. Those who advise
decision makers must assure that the decision makers are aware of the
values of resources and natural processes that cannot be easily
quantified.
The draft report points to a need for better performance management. We
would welcome increased emphasis on performance management, but we want
performance managers to understand the difficulty and complexity of
applying performance measures to land management situations involving
the interaction of multiple biological communities and diverse
populations of existing and new organisms. A simple example will
demonstrate this.
Suppose a land management agency has one million acres of weeds. If
they treat one percent of the infested acres per year, or 10,000 acres,
it would seem that they should be able to reduce the number of infested
acres to zero in one hundred years. This is far from true.
Some weeds spread slowly while other spread very rapidly. For large
scale planning purposes, weed scientists often assume an average spread
or rate of increase of 15 percent per year. Therefore, if you begin
with one million infested acres and treat 10,000 acres, at the end of
the year you will have an infested area of 1 million minus 10,000 acres
treated, plus 148,000 newly infested acres (990,000 x 0.15) for a total
of 1,138,000 acres. This is the situation faced by most Federal land
managers today. Presently, our objectives are to slow the spread of
weeds and to try to target the most critical species and acres.
Further, we are never finished with the 10,000 acres treated. They must
be periodically monitored and may require periodic retreatment. In many
cases, planting the sites with native species, a costly and difficult
process, would offset the need for retreatment. The agency will reach a
point where the monitoring of treated acres and retreatment will
require 100 percent of its weed management budget.
Finally, we would like to make one technical comment. The draft report
suggests that we should develop biological controls for potential
invaders before they arrive in North America so those biological
controls will be available for rapid responses. This would be extremely
expensive, especially when you consider that some of the potential
invaders may never reach our shores or may be intercepted at the ports
of entry. More importantly, biological controls, even if they are
available, are not an effective tool for rapid responses. Biological
controls work very slowly and can reduce but not exterminate
established populations. They would have little or no impact on
incipient populations.
We appreciate the opportunity to offer our perspectives on the draft
report.
[End of section]
Appendix IV: Comments from the Department of State:
United States Department of State Washington, D. C. 20520:
OCT 16 2002:
Dear Ms. Westin:
We appreciate the opportunity to review your draft report, “INVASIVE
SPECIES: Clearer Focus and Greater Commitment Needed to Effectively
Manage the Problem,” GAO-03-25, GAO Job Code 360158.
The Department’s comments are enclosed for incorporation as an appendix
to the GAO final report, along with comments from the International
Joint Commision (IJC). Please find technical comments attached as well.
If you have any questions, regarding this response, please contact Dana
Roth, Office of Ecology and Terrestrial Conservation, Bureau of Oceans
and International Environmental Scientific Affairs on (202) 736-7426.
Christopher B. Burnham:
Assistant Secretary of Resource Management and
Chief Financial Officer:
Signed by Christopher B. Burnham:
Enclosure:
As stated.
cc: GAO/NRE - Mr. Wood State/OIG - Mr. Berman State/OES - Ms. Stephens:
Ms. Susan S. Westin, Managing Director, International Affairs and
Trade, U.S. General Accounting Office.
Department of State Comments on GAO Draft Report:
INVASIVE SPECIES: Clearer Focus and Greater Commitment Needed to
Effectively Manage the Problem, (GAO-03-25, GAO Code 360158):
The Department of State and the International Joint Commission (IJC)
appreciate the opportunity to comment on the draft report INVASIVE
SPECIES: Clearer Focus and Greater Commitment Needed to Effectively
Manage the Problem, and both noted the comprehensiveness of the report.
IJC’s comments follow those of the Department of State.
The Department of State places a high priority on accomplishing the
goals of the National Invasive Species Management Plan, and this
priority is reflected in the attention the Department has devoted to
the invasive species issue and the progress we have made, as outlined
below. At least in relation to the Department’s activities, we
therefore do not fully concur with the finding of the GAO report that
attributes slow progress on the management plan to lack of priority
given to the plan by the Council and departments (e.g., p.32).
* Over the last four years, the Department of State has increased
resources to work on the invasive species issue. Currently, there is an
American Association for the Advancement of Science Fellow employed
full-time in OES/ETC who works almost exclusively on this issue.
* The Department coordinates the inter-agency process for the
Convention on Biological Diversity that addresses invasive alien
species. The agencies have worked with the Department over many hours
to develop a strong work program, and many agencies were actively
engaged on this issue at this international meeting.
* The Department has funded several regional workshops with the Global
Invasive Species Programme to help build cooperation to address this
global problem. The Department with other USG agencies has helped
facilitate the development of strategic plans to address the invasive
species problem in several regions, including South and Southeast Asia,
Southern Africa, Nordic-Baltic (which the Department has funded a
follow-up workshop on information systems for invasive species), and
South America. (“Recommendations” statements from our most recent
workshops are attached, for your interest.):
* The Department is actively participating in the International
Maritime Organization negotiations on development of ballast water
standards (which is ongoing, Oct. 2002).
* The Department actively participates in the various relevant task
teams set out in the National Invasive Species Management Plan and in
the Advisory Committee meetings.
* The Department co-chairs the North America strategy task team, and
participates in other North American fora that address invasive alien
species.
* The Department takes an active role in raising awareness of the
invasive species issue in bilateral and multilateral negotiations.
The following comments were provided by IJC:
The report highlights the sensitivity of the Great Lakes ecosystem to
invasive species yet fails to recommend any action to protect this
resource. Suggest that in its recommendations the GAO consider adding
comment under action for executive.
In the face of the continuing invasion of the Great Lakes by invasive
species, take action, in coordination with the government of Canada, to
develop an effective approach to immediately improve the management of
all ballast waters coming into the Great Lakes:
Add an action for Congress:
To continue strong support for invasive species control, promptly
complete action on reauthorization of NISA.
Attachment: Final Recommendations, Arising from 2001 - 2002 Regional
Workshops on Invasive Alien Species:
[End of section]
Appendix V: Comments from the National Invasive Species Council through
the Department of the Interior:
United States Department of the Interior:
OFFICE OF THE SECRETARY Washington, D.C. 20240:
OCT 15 2002:
To: David G. Wood, Director of Natural Resources and Environment U.S.
General Accounting Office:
Through: Dr. Jim Tate, Science Advisor to the Secretary U.S. Department
of the Interior:
Mr. Tim Keeney, Deputy Assistant Secretary for Oceans and Atmosphere,
U.S. Department of Commerce:
Dr. Jim Butler, Deputy Assistant Secretary for Marketing and Regulatory
Programs, U.S. Department of Agriculture:
From: Lori Williams, Executive Director, National Invasive Species
Council:
Subject: Council Comments on GAO report, Invasive Species:
Clearer Focus and Greater Commitment Needed to Effectively Manage the
Problem (GAO-03-01) - DRAFT:
Attached are the comments of the National Invasive Species Council on
the subject GAO report. This draft has also been sent to the Council
member departments for their comment and approval. The co-chair
departments are also providing separate comments to GAO.
I can be reached at 202-513-7243 should you need to discuss these
comments further.
National Invasive Species Council Comments on the Draft GAO Report
entitled, Invasive Species: Clearer Focus and Greater Commitment Needed
to Effectively Manage the Problem (GAO-03-01):
Comments on Recommendations:
The Council concurs with the recommendation that the upcoming revision
of the National Invasive Species Management Plan (Plan) the goal of
incorporating information on the economic impacts and relative risks of
different invasive species or pathways in the formulation of an
invasive species crosscut budget. The Council notes that the current
Plan (see, action items #44 and 46(a) under Research) calls for
additional research on the economic impacts of invasive species, and
increased emphasis on risk analysis (see: action items # 14, 15 and 19
under Prevention). The Council also concurs with the note of caution
that
determining in advance what species are likely to be invasive through
unintentional introductions could be problematic, as stated in the
Department
of Commerce comments on this section.
The Council agrees that better performance measures should, and will,
be included in the revised version of the Plan. However, it is
important to note that the Management Plan was this nation’s first
attempt to draft a comprehensive blueprint on how to deal with invasive
species issues across 23 Federal agencies and coordinate with state,
local and private entities. The Plan has and continues to be used as a
model for planning efforts by numerous states and other nations,
including Canada. The Council is including performance measures in the
current draft of the invasive species crosscut budget. It is also
important to recognize that for many invasive species, baseline data
may be lacking. Additionally, some activities essential to dealing with
invasive species issues, including some elements of prevention (how do
you confirm the absence of a species?), education and outreach, and
research may not be easy to measure, at least in the near term. Despite
these important caveats, the Council is supports including realistic
and attainable performance measures as part of the revised Plan.
The Council concurs that action item # 1 of the Plan establishing a
transparent oversight mechanism for use by Federal agencies in
complying with Executive Order 13112, be given a high priority.
The Council concurs that an evaluation of whether there should be
statutory authority for the Council should be conducted.
It is appropriate for the Council’s individual members to respond to
the final recommendation concerning their individual annual performance
plans. The Council stands ready to assist in this effort. The Council
notes that each member department and agency operates on different
timelines regarding their performance and strategic plan.
General Comments:
Although the Council agrees that progress to date on completing action
items in the Plan has been disappointing and is taking steps to
accelerate progress, it is important to realize that the deadlines in
the Plan were optimistic, given current resources and funding. As noted
in the comments of the Department of Commerce, the report fails to
evaluate whether the original deadlines contained in the Plan were
realistic and attainable. The report underestimates progress under the
report in the following ways:
1) It sites as progress, only those items (except in a few noted cases)
that have been competed. This is despite the fact that GAO gathered a
significant amount of information from the Council staff and the
departments about progress toward completion of 40 to 50 percent of the
action items --in addition to those completed. Many of the items in the
Plan represent ambitious, broad goals requiring multi-agency planning,
implementation, and sign-off --and reporting on progress toward those
goals is important. For example, progress toward achieving a common
monitoring protocol for invasive plants represent a significant step,
despite the need to complete work on other taxa.
2) Progress toward an action item under the Plan by departments and
agencies --either individually or as a group --is significant progress;
regardless of if complete coordination has occurred or if a specific
Council task team has been formulated. This especially applies to those
where one or more lead agencies are identified in the Plan. Now that
implementation task teams have been formulated, they are utilizing and
building upon the work has already done by individual agencies or
departments. Prior progress achieved individually or collectively will
significantly expedite future progress on action items that have been
the focus of departmental and agency efforts. For instance, the
Pathways task team is using lists of pathways already developed or
being developed by a number of agencies as initial input for completing
action item #20.
3) The status of the implementation teams (by Federal agency officials)
was built upon the scoping teams’ work, and the entire process should
be considered in the evaluation. This will be explained in more detail
in the specific comments. In the scoping process, Federal members of
the teams
(representing all Council member departments and agencies, not the
Council staff or liaisons) met and approved draft procedures,
identified key stakeholders, set priorities for work. They also decided
individually whether it was important to include nonFederal
stakeholders in the formulation of their group. This was done in
advance of the formulation and approval of joint Federal/nonFederal
subcommittees and task teams under the Invasive Species Advisory
Committee. Current implementation teams have relied upon this work to a
great extent.
There seems to be a misunderstanding about the role and function of the
Plan implementation task teams and subcommittees. It should be noted
that specific actions under the Plan (in almost all cases) must be
implemented by those specific agencies and departments with budgetary
and regulatory authority or appropriate an authorized program. Those
specific departments and agencies must carry out the actual
implementation of details involved with each action item with
responsibility. Therefore, the role of the implementation teams is to
provide general, overall guidance, ensure all the key action agencies
are identified, set priorities among the many items in the Plan and
provide for coordination with outside groups and stakeholders, if
appropriate.
In general, the report undervalues progress toward increased
coordination and cooperation among Federal agencies and departments on
invasive species. The Council has assisted with coordination of
legislative issues and briefings related to invasive species. As noted,
the current effort to draft an invasive species crosscut budget
proposal for FY04 has resulted in significant coordination efforts on
budget and performance management issues, especially among the three
Co-chair departments. The report fails to note monthly meetings devoted
to coordination among the ten Council member liaisons. Working closely
with the State department, the Council assisted with coordination and
formulation of international positions regarding the International
Plant Protection Convention, and the Convention on Biological
Diversity, among others. Further examples are contained in the specific
comments below, and in the comments of individual member departments.
Specific comments:
P. 6 - It is important to clarify whether the report is referring to
non-native, or invasive species.
P. 11-The Council does not have a Risk Analysis Specialist or a Website
Coordinator currently on the staff, nor has either been identified as a
future position. Richard Orr assisted with risk analysis while he was
on detail with the Council and is included in the Plan as a Council
staff member. The National Agricultural Library manages our website on
a day-to-day basis. Along with his other duties, Chris Dionigi
(Domestic Policy Assistant Director) currently manages the website for
the Council. The Council Co-chairs are currently evaluating the
Council’s staffing needs.
P. 13 - Note in discussion of economic impacts that action items 44(a)
and 46(a) call for increased research at the national and international
level on the economic impacts of invasive species.
P. 23 - The Council believes that the Plan is a very positive, initial
overall blueprint for Federal action to deal with invasive species. It
contains important elements that need to be implemented to address this
serious problem. Future revisions of the Plan should, and will, include
more specific performance criteria and address the perceived
deficiencies in the Plan, which will improve the Plan overall.
P. 24 - Including a specific performance measure regarding reducing the
introduction of new species by a certain percentage would be
problematic at this time. We do not have baseline data indicating the
number of introductions now occurring. This example demonstrates the
challenge of measuring exact performance for prevention activities.
P. 24 -The draft report appears to emphasize the response of nine (as
opposed to the majority of 17) respondents who said that the plan is
focused on the most important issues? This response seems to indicate a
strong degree of support by ISAC members for the Plan. In addition, the
Council believes all the members of ISAC are “prominent” in there
fields and therefore are chosen to serve on ISAC.
P. 25 - The second paragraph quote of the Executive Director is
incomplete and misleading. The important factors are that this was the
first attempt to draft a comprehensive, Federal blueprint for managing
and dealing with a wide range of taxa of invasive species for 23
Federal agencies. Given the scope of this first-time effort, it was
unrealistic and difficult to also agree on specific measurable goals.
(The current DAS for DOI was not present during the drafting or
approval of the Plan. His statement is accurate, however it is
important to note that the Plan underwent full departmental and OMB
review as well as public notice and comment. Budget and performance
management staff were not excluded from the process.):
P. 25 - The crosscut proposal for FY04 represents a very significant
effort; however as a first attempt, it will not represent the totality
of invasive species expenditures or efforts. It will emphasize certain
efforts and primarily focus on the activities of the three Council Co-
chairs.
P. 26 - The Council has provided extensive information about the
progress of departments and agencies in addressing action items in the
Plan. Council staff has also provided oral updates at most ISAC
meetings. GAO staff observed many of the ISAC meetings, during which,
they were provided with much of this information. A written, overall
summary of progress is due to be completed in the next month.
P. 31-Work sited here is being utilized by Council implementation task
teams, and is part of the crosscut budget discussions. Progress by
individual agencies is crucial to progress under the Plan. [See text of
general comments]
P. 31-The Executive Director did not say that it was improper to
‘debate the agencies’. The Director stated that while some of the
agency reports did not seem to directly link to specific action items,
many if not most of the agency actions were accurate and helpful
progress reports. In the Director’s view, it is difficult and
counterproductive for Council staff to second-guess agencies have the
expertise in these areas and believe their actions are relative to the
Plan. In addition, the reporting of invasive species activities (even
if not directly linked to the Plan) is important for overall
coordination purposes, and useful to the Council.
P. 32 - The Executive Director did not say that there was “no reason to
form implementation teams” until after the Plan was finalized. The
Council departments and OMB had not approved the final Plan, and all
comments had not been incorporated. It would have been inappropriate to
formulate teams to implement a Plan that had not been approved or
finalized.
P. 32 - The timeline is missing an important bullet and many actions
that took place before the expiration of the terms of the last ISAC.
Also, ISAC as a body did not expire. The charter for ISAC was renewed,
and therefore the Committee itself continued to exist. What expired
were the terms of the former ISAC members. Now terms are staggered
among members to avoid future problems (This action has already been
taken).
The missing bullet concerns the request by Council Federal officials to
consider whether, how and who should formulate Plan implementation
teams. This process began in June and July of 2001, well before I SAC
terms expired. Those Federal officials from the Council who were
interested met to discuss each of the teams proposed at the
Shepherdstown meeting. (See the “Scoping” memorandum and draft terms of
reference provided by Council staff to GAO.) At the scooping meetings,
Federal officials agreed upon draft terms of reference (or operating
procedures), discussed lead agencies, set initial priorities, and
decided (at each scooping meeting for each team) whether non-Federal
members should be included and thus the team should be formulated under
ISAC. In most cases, Federal members were designated after these
meetings. In all cases, the scoping meetings concluded non-Federal
participation was desirable.
P. 33 - By the time scooping was completed for all the teams in the
fall, the process for choosing new ISAC members had begun. This did
result in a delay of further meetings as suggested until the new ISAC
was formulated and met in May and June 2002. The teams that have met
thus far have relied greatly on the earlier work done by the Federal
scooping meetings.
Final bullet should read, “all but two of the teams (International and
Budget) include both Federal and non-Federal members.”:
As clarified above, the Executive Director did not state that there was
any single decision made at one time to include non-Federal members on
all implementation teams. In addition, Federal members made decisions
during scoping; and by ISAC members for each individual team. The
importance of getting consensus and participation by key stakeholders
has been a critical factor in the decision making process.
P. 34 - Please see the Council’s General Comments about the
misunderstanding of the role of the implementation teams. The ISAC does
not have the authority in their Charter or otherwise to make decisions
about implementing the plan at the Federal level. Those specific
decisions are made by the appropriate agencies and departments with the
legislative, budgetary and regulatory authority to take such actions.
The implementation teams might more properly be termed “implementation
guidance teams” and are not:
charged with making the type of decisions GAO references in this
paragraph as inappropriate and outside the scope of ISAC’s charter.
The Council agrees that the delays have been unfortunate, but believes
strongly in the value of getting stakeholder input, assistance and
expert guidance in determining how many elements of the Plan should be
implemented. Invasive species is not solely, or even primarily a
Federal problem. Solutions cannot be solely Federal and would be
successful if implemented in a vacuum. The Council supports looking
carefully at the Plan action items to be implemented, and determining
the best mechanism on a case-by case basis rather than excluding non-
Federal members from all Plan implementation guidance teams.
[End of section]
Appendix VI: Comments from the Environmental Protection Agency:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460:
OCT 11 2002:
Mr. David C. Wood:
Director, Natural Resources and Environment U.S. General Accounting
Office Washington, DC 20548:
Dear Mr. Wood:
Thank you for the opportunity to comment on the General Accounting
Office (GAO) draft report entitled, Invasive Species: Clearer Focus and
Greater Commitment Needed to Effectively Manage the Problem (GAO-03-
01), received on September 25, 2002.
As requested in your recent letter to Administrator Whitman, we are
pleased to provide EPA’s comments on the draft report. These were
developed by our intra-agency Non-indigenous Species Work Group,
comprised of representatives from our programs as well as our regional
offices. The work group is very familiar with the invasive species
problem and has been involved in the development of the Management Plan
(hereinafter referred to as “the Plan”) pursuant to the Executive Order
13112 on Invasive Species.
While the recommendations in the report seem reasonable, the
conclusions are based on a survey of only 23 respondents. Nonetheless,
we believe adoption of the recommendations would enhance the federal
government’s approach to dealing with the problem of invasive species.
The draft report is especially noteworthy because it: (1) highlights
why existing analyses of the economic impacts of invasives are of
limited use to decision-makers; (2) describes why good models must be
developed to predict the spread of invasives as well as their ecosystem
and economic impacts; (3) highlights how few resources agencies are
allocating to invasives’ activities; and (4) highlights major
limitations of the National Invasive Species Management Plan, including
the fact that it isn’t a strategic plan with measurable goals and
environmental outcomes, but is instead an inventory of planned agency
actions.
Although the report is a curious mix of economic theory, ballast water,
and a review of the National Invasive Species Council (NISC), we found
it to be well-written and helpful in assessing the progress made in
coping with invasive species. We believe the report could be
strengthened, however, if it focused more on the NISC and the Plan. In
particular, we suggest that the report focus on four questions: (1) is
the NISC being managed efficiently given the various limitations; (2)
do the members have sufficient resources (budget and full-time
equivalents) to achieve their action items; (3) what progress has been
made to achieve their action items; and (4) is the extent of progress
commensurate with available resources?
Recycled/Recyclable . Printed with Vegetable Oil Based Inks on 100%
Recycled Paper (40% Postconsumer):
In addition to these general comments, there are several issues that we
want to bring to your attention.
1. We believe that members of the Invasive Species Advisory Committee
(ISAC) should not serve on federal committees intended to implement the
Plan. While EPA salutes the excellent job the NISC and its staff have
done to reach out to constituent groups and stakeholders, mixing
federal with non-federal staff on implementation committees has, in our
opinion, led to some confusion and delays in implementing the Plan. It
is the federal government that is responsible for implementing the
Executive Order and not a Federal Advisory Committee (FACA). A FACA can
only advise and should not be responsible for implementation.
2. As previously stated, we believe that GAO’s somewhat critical view
of the Plan and the concern over the lack of progress in implementing
the Plan are based on a survey of only 23 respondents. Further, these
respondents were or are members of the ISAC and likely do not have
unbiased perspectives. While it is true that the pace of implementation
has not been as fast as the immigration of new invasives, we wonder if
it is suitable to base the conclusions on such a small sample. The tone
of the GAO report might be different if more of the federal agency
staff and state resource managers were surveyed.
3. While the concept of performance measures is laudable, in most cases
they will have to be regional and species specific. An example with
vector control might be “to reduce the rate of new introduction into
San Francisco Bay by 50% by 2010.” But these standards would not apply
to other west coast ports, which have different invasion rates,
susceptibility, etc. Also, in many cases (except perhaps with
agricultural pests), we do not have the baseline information to
determine if we have achieved the standard. As written, the draft
report comes across somewhat voluble regarding performance standards.
We believe the document should recognize the difficulties of
identifying and measuring performance standards in ecological systems
being stressed by a highly stochastic stressor.
4. We believe the ballast water section is very “Great Lakes centric.”
We realize that there has been much attention given to the Great Lakes,
but there is also work being done in marine and estuarine waters. The
effects of invasive species on these ecosystems should be expanded, and
the need for research, prevention, and control in this area should
receive more emphasis. The Smithsonian Environmental Research Center
maintains a clearinghouse of information related to biological
invasions from ballast water discharges.
In addition to these general comments, we have enclosed detailed
comments on specific portions of the text that should provide
additional clarification of EPA’s position on key issues raised by the
draft report.
We appreciate the opportunity to respond to this draft report. Should
you have questions of would like additional information, please contact
Mr. Michael Slimak on 202-564-3324 or slimak.michael@epa.gov.
Paul Gilman:
Science Advisor to the Agency:
Signed by Paul Gilman:
[End of section]
FOOTNOTES
[1] A concept basic to invasiveness is that these species have been
introduced into an environment in which they did not evolve; thus, they
usually have no natural enemies to limit their spread.
[2] U.S. General Accounting Office, Invasive Species: Federal and
Selected State Funding to Address Harmful Nonnative Species, GAO/
RCED-00-219 (Washington, D.C.: Aug. 2000) and Invasive Species:
Obstacles Hinder Federal Rapid Response to Growing Threat, GAO-01-724
(Washington, D.C.: July 2001).
[3] Council members include the Secretaries of State, Defense,
Treasury, Agriculture, Commerce, Transportation, Health and Human
Services, and the Interior, and the administrators of the Environmental
Protection Agency and the U.S. Agency for International Development.
The Secretaries of Agriculture, Commerce, and the Interior are the
cochairs of the council.
[4] Ballast water is deliberately pumped into tanks within a ship to
control or maintain the trim, draft, stability, or stresses of the
vessel. Because ballast water is pumped from oceans or rivers, it can
contain living aquatic organisms found in those locations.
[5] GAO/RCED-00-219.
[6] See GAO/RCED-00-219. The Department of the Treasury’s Customs
Service, the Department of Health and Human Services, and the
U.S. Agency for International Development also have expenditures
related to invasive species but were not included in our report.
[7] The Secretary of Health and Human Services and the Administrator of
the U.S. Agency of International Development were not specifically
named as members of the council by the executive order, but were
invited to join as permitted by the executive order. The Secretary and
Administrator joined the council in February 2001.
[8] See Voluntary Guidelines for the Control of Ballast Water
Discharges from Ships Proceeding to the St. Lawrence River, which were
superceded in 2000 by the Guidelines for the Control of Ballast Water
Discharge from Ships in Waters Under Canadian Jurisdiction and amended
in 2001. Even though the guidelines are voluntary, the Canadian Coast
Guard can impose a fine under the Canada Shipping Act for an operator
who knowingly provides false information to a vessel traffic regulator.
[9] P.L. 101-646 (1990), as amended by the National Invasive Species
Act of 1996, P.L. No. 104-332 (1996), codified at 16 U.S.C. §§
4701-4751.
[10] 33 C.F.R. §§ 151.1500-151.1516.
[11] While we examined estimates of the impact of invasive species with
respect to their scope and methodology, we did not attempt to verify
the accuracy of the estimates of economic impact.
[12] Federal Interagency Committee for the Management of Noxious and
Exotic Weeds, Invasive Plants: Changing the Landscape of America, Fact
Book, Washington, D.C.: FICMNEW, 1998.
[13] All dollars in this section were adjusted to 2001 dollars unless
otherwise noted.
[14] Economic damages to natural ecosystems are measured in terms of
individuals’ willingness to pay for the goods and services provided by
an ecosystem. For example, the gain in value associated with a specific
improvement in environmental quality, such as a day of birding in a
natural ecosystem that has been freed of invasive species, is measured
by an increase in people’s willingness to pay for this experience.
[15] Lee and Chapman, Nonindigenous Species-An Emerging Issue for the
EPA, Vol. 2, U.S. EPA, May 2001, available on the Web from http://
www.epa.gov/owow/invasive_species/workshop/nisvol2.pdf.
[16] U.S. Congress, Office of Technology Assessment, Harmful Non-
Indigenous Species in the United States, OTA-F-565, Sept. 1993,
available on the Web from http://www.wws.princeton.edu/~ota/disk1/
1993/9325_n.html.
[17] Pimentel et al., “Environmental and Economic Costs Associated with
Non-Indigenous Species in the United States,” BioScience, Jan. 2000.
This estimate has not been adjusted for inflation. The researchers
combined dollar estimates representing different years from different
studies without adjusting them for inflation.
[18] USDA, APHIS, Pest Risk Assessments: Pest Risk Assessment for
Importation of Solid Wood Packing Materials into the United States,
App. B: Case Histories of Previous Introductions of Forest Pests,
Aug. 2000, available on the Web from http://www.aphis.usda.gov/ppq/
pra/swpm/.
[19] Hirsch and Leitch, “The Impact of Knapweed on Montana’s Economy,”
Agricultural Economics Report No. 355, Department of Agricultural
Economics, North Dakota State University, July 1996.
[20] Lafferty and Kuris, “Biological Control of Marine Pests,” Ecology,
77(7), Oct. 1996.
[21] Lafferty and Kuris.
[22] Quinn, “Workshop on development of regional invasive species
information hubs in North America and Southern Africa,” Aliens
newsletter, World Conservation Union, No. 13, 2001, available on the
Web from http://www.issg.org/aliens_newsletter/Aliens13.pdf.
[23] National Science and Technology Council, Committee on Environment
and Natural Resources, Ecological Risk Assessment in the Federal
Government, CENR/5-99/001, Chapter 4: Nonindigenous Species, May 1999,
available on the Web from http://www.nnic.noaa.gov/CENR/ecorisk.pdf.
[24] Nico and Williams, “Risk Assessment on Black Carp,” USGS, Report
to the Risk Assessment and Management Committee of the Aquatic Nuisance
Species Task Force, Oct. 1996.
[25] 67 Fed. Reg. 49280 (July 30, 2002).
[26] Orden, Narrod, and Glauber, “Least Trade Restrictive Sanitary and
Phytosanitary Policies: The Analytic Framework Is There, the Specific
Answers Are Not,” Oct. 2000, available on the Web from http://
www.usda.gov/agency/oce/oracba/papers/orden.htm.
[27] 60 Fed. Reg. 34832 (July 3, 1995).
[28] 62 Fed. Reg. 24753 (May 6, 1997).
[29] Leuschner et al., “Potential Benefits of Slowing the Gypsy Moth’s
Spread,” Southern Journal of Applied Forestry, 20(2), 1996.
[30] Halstead et al., “An Hedonic Analysis of the Effects of an Exotic
Invader (Myriophyllum heterophyllum) on New Hampshire Lakefront
Properties,” paper presented at the Annual Conference of the
Northeastern Agricultural and Resource Economics Association, Bar
Harbor, Maine, June 2000.
[31] Cohen, “Evaluating the Risks of Importation of Exotic Pests Using
Geospatial Analysis and a Pest Risk Assessment Model,” Proceedings of
the First International Conference on Geospatial Information in
Agriculture and Forestry, Lake Buena Vista, Florida, June 1998,
available on the Web from http://www.aphis.usda.gov/ppd/
evaluating.pdf, (building on Orr et al., “Generic NonIndigenous Pest
Risk Assessment Process,” USDA, APHIS, Nov. 1993).
[32] Ahl, “The Role of Risk Analysis in Integrated Pest Management,” in
K. Smith, Reducing Environmental and Health Risks from Agricultural
Chemicals; Policy Considerations, available on the Web from http://
ers.usda.gov/publications/mp1542/MP1542e.PDF.
[33] The task force was established pursuant to the Nonindigenous
Aquatic Nuisance Control and Prevention Act of 1990 to coordinate
government efforts related to nonindigenous aquatic species in the
U.S.with regional, state, and local entities. It is cochaired by the
Fish and Wildlife Service and the National Oceanic and Atmospheric
Administration. “Generic Nonindigenous Aquatic Organisms Risk Analysis
Review Process,” report to the Aquatic Nuisance Species Task Force,
Oct. 1996, available on the Web from http://www.anstaskforce.gov/
gennasrev.htm.
[34] Aquatic Nuisance Species Task Force, “Guidance for State and
Interstate Aquatic Nuisance Species Management Plans,” Nov. 2000,
available on the Web from http://www.anstaskforce.gov/
state_guidance.htm.
[35] Keppner and Caplen, “A Prevention Program for the Mediterranean
Strain of Caulerpa taxifolia,” submitted to the Aquatic Nuisance
Species Task Force, Aug. 1999, available on the Web from http://
www.anstaskforce.gov/Caulerpa.htm.
[36] National Plant Board, Preventing the Introduction of Plant
Pathogens: The Role and Application of the “Systems Approach” (draft
document), Feb. 2002, available on the Web from http://
www.aphis.usda.gov/ppq/systemsapproach/.
[37] Risk Assessment Review Standards, USDA Animal and Plant Health
Inspection Service, Aug. 2001.
[38] National Invasive Species Council, Meeting the Invasive Species
Challenge: Management Plan, 2001.
[39] P.L. 103-62 (1993).
[40] The plan called for several of the actions to start by a certain
date, while most were to be completed by a certain date.
[41] To avoid the problem of the advisory committee becoming
temporarily inactive, the Executive Director told us that the council
has modified the terms of the advisory committee members so that half
have 2-year terms and half have 3-year terms. As a result, the
committee will operate continuously.
[42] The council’s budget summary did not include data for all relevant
agencies. Missing were data from the Army Corps of Engineers, the
Environmental Protection Agency, and the Bureau of Reclamation.
[43] These requirements also apply to ships traveling in the Hudson
River north of the George Washington Bridge in New York. The National
Invasive Species Act also tasked the Secretary of Transportation with
promulgating voluntary national ballast water guidelines. On May 17,
1999, the Coast Guard promulgated interim voluntary guidelines,
including ballast water exchange, applicable to vessels entering U.S.
waters from outside the Exclusive Economic Zone and calling on U.S.
ports other than those in the Great Lakes or on the Hudson River. The
guidelines became final December 21, 2001. They also require that
arriving ships report information on their ballast water, although they
do not impose penalties for nonreporting.
[44] The National Invasive Species Act currently allows vessels to use
alternative environmentally sound ballast water management methods but
requires that they be “as effective as ballast water exchange” in
preventing and controlling the influx of aquatic organisms; under the
regulations, the Coast Guard Commandant must first approve their use.
To date, no alternative methods have been approved.
[45] In contrast, compliance with the mandatory reporting requirements
that apply to the rest of the country has been low. A Coast Guard
official testified before the Congress on May15, 2002, that the
consistently low rate of reporting makes it impossible to accurately
assess compliance and effectiveness. Congress mandated that the
voluntary ballast management guidelines become mandatory if the
Secretary of Transportation determines that compliance is low.
[46] As with an earlier shipborne invader known as the spiny water flea
(Bythotrephes cederstroemi), scientists are studying the fish-hook
water flea’s impact on zooplankton biomass. Zooplankton is a common
item in young fishes’ diets and the fish-hook water flea has the
potential to disrupt fish populations by preying on their food supply.
In addition, the fish-hook water flea clumps together into large mats
that tangle fishing lines, which could adversely affect the commercial
and recreational fishing industries. The amphipod Echigogammarus
ischnus was first discovered in the Detroit River in 1995, where it
occupied a habitat typical of the native amphipod Gammarus fasciatus,
suggesting the possibility of competition between the two species.
[47] The salinity of seawater varies in various parts of the ocean from
30 to 39 parts per thousand, but is fairly close to 35.5 parts per
thousand in the middle of the North Atlantic.
[48] 67 Fed. Reg. 8885 (Feb. 27, 2002).
[49] A recent study analyzing the market for future treatment
technologies reported that there are over 47,000 vessels in the world
fleet where ballast water treatment technologies could be applicable.
[50] The Boundary Waters Treaty of 1909 established the International
Joint Commission. The treaty established the commission to, among other
things, advise the U.S.and Canadian governments concerning
transboundary water quality issues. The commission has six members;
three appointed by the President of the United States, with the advice
and approval of the Senate, and three appointed by the Governor in
council of Canada, on the advice of the Prime Minister. The Great Lakes
Fishery Commission was created in 1955 by the Convention on Great Lakes
Fisheries between the U.S.and Canada.
[51] The National Invasive Species Act is due for re-authorization in
2002. House and Senate re-authorization bills, H.R. 5396 and S. 2964,
respectively, were introduced on September 18, 2002.
[52] The commission also recommended that the governments of the United
States and Canada develop uniform protocols for performance testing of
ballast water and ensure that all ships built after a certain date have
treatment technology incorporated into their construction to be allowed
entry into the Great Lakes.
[53] Several states outside the Great Lakes have passed ballast water
legislation, including California, Hawaii, Maryland, Oregon, Rhode
Island, and Washington. None of these laws require sterilization.
[54] 40 C.F.R. § 122.3(a). This program regulates pollutant discharges
to the nation’s waters.
[55] The IMO is an organization of 160 member countries with observers
from governmental, industry, environmental, public interest, and labor
organizations. To achieve its objectives, the IMO has promoted the
adoption of some 30 conventions and protocols, and has adopted well
over 700 codes and recommendations concerning maritime safety, the
prevention of pollution, and related matters.
[56] The Coast Guard has estimated the impact of ballast water
regulations on the shipping industry but has not done a comprehensive
analysis of the benefits that the regulations would yield or the costs
of inaction. The only specific economic impact cited by the Coast Guard
as justification for the regulations was the cost of the zebra mussel
infestation.
[57] Great Lakes Water Quality Board, Report to the International Joint
Commission, Alien Invasive Species and Biological Pollution of the
Great Lakes Ecosystem (Windsor, Ontario: May 2001).
[58] Knight et al., Detection and Enumeration of Fecal Indicators and
Pathogens in the Ballast Water of Transoceanic Cargo Vessels Entering
the Great Lakes, 1999.
[59] According to EPA, in 1998, the United States and Canada called
upon the International Joint Commission to help the two countries
develop and implement new and improved binational approaches to manage
and protect major shared watersheds. Aquatic invasive species would be
covered by this long-term initiative.
[60] The Great Lakes Panel is made up of U.S. and Canadian federal
officials and representatives from the eight Great Lakes states and the
province of Ontario.
[61] U.S. General Accounting Office, Foot and Mouth Disease: To Protect
U.S. Livestock, USDA Must Remain Vigilant and Resolve Outstanding
Issues, GAO-02-808 (Washington, D.C.: July 2002).
[62] The term “phytosanitary” refers to measures taken to prevent the
introduction and/or spread of plant pests.
[63] The task force does have Canadian representation in an “invited
observer” status.
[64] This organization was created under the auspices of the North
American Agreement on Environmental Cooperation, which complements the
environmental provisions of the North American Free Trade Agreement.
[65] Member agencies are the U.S. Fish and Wildlife Service, the
Canadian Wildlife Service, and Mexico’s Ministry of Environment and
Natural Resources.
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